29JAPAN LAWYERS GUIDE 2018/19Arclesthat take advantage of Japanese tradition, culture, art or other features;(v)Facilities that contribute to the promotion of tourism in Japan by properly providing information about tourist attractions in each region and also providing one-stop services to arrange transport, accommoda-tion and other matters necessary for sight-seeing vis-its to each region;(vi)Lodging facilities that meet the sophisticated and di-versied needs of users; and(vii)In addition to the foregoing, facilities that otherwise contribute to promoting tourism by domestic and foreign tourists.b.Number of IRs to be establishede number of IR Areas shall be limited to three (3) for the time being (Article 9 of the Act). However, after ve (5) years have elapsed from the date of the rst certica-tion, the government shall review the status of enforce-ment of the Act and shall take necessary measures (if any) based on the results thereof. In this context, the number of IR Areas will be specically reviewed after seven (7) years have elapsed from the date of the rst certication (Article 4 of Supplementary Provisions to the Act).c.Size of casino faciliesWhile the Act is still silent on the actual limitation on the size of casinos as this has been relegated to the Cabinet Order (Article 41 of the Act), the work-ing team of the ruling party issued their opinion regarding the maximum size of casino floors. The working team recommends that, considering that the location and size of the IR has yet to be defined, rather than setting a limitation on the absolute val-ue, the gross floor area for the casino in IR facilities shall be limited to 3% or less. e basis of the calculation shall be 3% of the “gross oor area” and not the land area, which should ensure the casino to be “only a part of the facilities.”d.Term of licensee term of casino license shall be three (3) years from the grant date of license (Article 43 (1) of the Act), which may be renewed for successive three (3) years pe-riods (Article (2) and (6) of the Act). Please note that the Area Development Plan, which would be a prereq-uisite for the casino license, also needs to be certied (and renewed) under a separate procedure, which is outlined below in more detail.e.Limitaon on the number of mes of entry and means to verify identyChapter VII of the Act provides for a strict limitation on the number of times of entry and entry fee to prevent problem gambling. While there is no limitation on the number of times of entry for non-Japanese residents, the Japanese residents are limited to “3 times in 7 days + 10 times in 28 (Article 69 of the Act), and “My Number cards” shall be utilized for the verication of identity and the number of times of entry (Article 70 of the Act).f.Entry feee entry fee will be imposed on Japanese residents in the amount of 6,000 yen, half of which shall be paid to the national government (Article 176 of the Act) and the other half to the local government (Article 177 of the Act).g.LevyWhile there was a discussion of whether a progressive levy system could be imposed, since this may reduce the incentive for entities to expand their business by additional investment and otherwise risks discouraging investment to realize the commonwealth, the levy was xed at the rate of 30% of gross gaming revenue, half of which shall be paid to the national government (Article 192 of the Act and the other half to the local govern-ment (Article 193 of the Act).h.Restricon on prot sharing of gaming revenueCasino Business Operator (as explained in the follow-ing section) is prohibited from entering into contracts that do not fall under certain criteria, one of which is that the provisions of such contract shall not stipulate payment of an amount calculated in proportion to the GGR nor any other amount calculated based on all or a part of the GGR (Article 94(i)(e) of the Act). 2.Persons, enes, policies and agreements that are of signicance under the ActSince the casino operation which would be conducted

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