The Japanese CFC rule consists of two approaches in general. One is the full inclusion and the other is the passive income inclusion (i.e the partial inclusion). The passive income consists of the following 12 types of income : (1) dividends, (2) interest, (3) securities-lending fees, (4) capital gains/losses derived from transfer of securities, (5) profits/losses derived from derivative transactions, (6) foreign exchange gains/losses, (7) income derived from financial transactions that is not covered by the item from (1) to (6), (8) insurance income (9) leasing fees of tangible assets, (10) royalties from intangibles, (11) capital gains/losses from transfer of intangibles and (12) abnormal income which is not arising from real economic activities.