Fumyo means a form of collecting tax or a contractor for collecting tax under the system of the dynasty state which began sometime around the Heian period of Japan. Around the tenth century, the Imperial Court abandoned the system of ruling over people which had originated in the Ritsuryo system (a system of centralized government based on the ritsuryo code) and moved to a system based of taxation of land (the system of the dynasty state).
The land that was reorganized into a unit of taxation on that occasion was called myoden (rice field lots in charge of a nominal holder), and the contractor for the management of the myoden was called 'fumyo.'
The Ritsuryo system of Japan, which was officially inaugurated in the eighth century, was an administrative system based on the control over people and farmers by koseki (the household registers) and keicho (the yearly tax registers) and the collection of land tax by Soyocho (a tax system, corvee), which was imposed in exchange for hankyu (allotment) of kubunden (the farm land given to each farmer in the Ritsuryo system). The reforms carried out by Emperor Kanmu from the late eighth century to the early ninth century also aimed at the above mentioned maintenance and enhancement of the Ritsuryo system domination. However, by the first half of the ninth century, the rule over people under the Ritsuryo system began to crumble from the ground up because a significant increase in the number of farmers escaping or going missing. In response to these social conditions, since the early part of the ninth century (during the period of administration of FUJIWARA no Fuyutsugu), there was a growing tendency to put emphasize on the tax on land. Although the policies to return back to the principles of the Ritsuryo system were implemented again from the late ninth century to the early tenth century (during the peaceful era of Kanpyo and the peaceful era of Engi), such policies eventually ended in failure. As a result, the attempt to go back to the rule over people under the Ritsuryo system was utterly-abandoned. There is also another widely accepted theory alleging that the policies in Kanpyo and Engi era were not attempts to return to the Ritsuryo system but preparation for the shift towards the system based on land.
In this way, the Imperial Court radically changed its system from ruling over people to governing through land. In this process, myoden became the basis of the administration of the land. The riso-fumyo system (a percentage/unit of the yearly land tax yield taken in by the manager of an estate), which appeared after the latter half of the ninth century, awarded the wealthy class a contract for suiko (government loans, often seed rice, made to peasants in Japan from the seventh through twelfth centuries). In the Engi era, however, kokuga in various provinces shifted the system from the conventional direct control over koden (field administered directly by a ruler, such as kubunden or joden) in the territory to a new system in which the koden was divided into units called myo, and the administration of each myo was contracted out to tato that was called 'rich class' in those days. This type of tato was called 'tato fumyo' (cultivator/tax manager). Tato fumyo was under the obligation to distribute taxes and assignments, such as kanmotsu (tribute goods paid as taxes or tithes) and zoyaku (odd-jobs tasks) to the kokuga in exchange for holding a commission from the kokuga to administrate each myo. This kind of tax collection system was called the fumyo system and formed the basis of the system of the dynasty state which had its origin during this period.
Tato fumyo was not allowed to privately own the myo. Instead, they were just awarded a contract to administrate the myo by the kokuga. Therefore, it is said that tato fumyo played the both roles of the ruled and the rulers, which means that they were the ruled for the kokuga, and they were the rulers for the general farmers. Tato fumyo was only obliged to fulfill the duties of distribution of land tax and assignments. The things related to the myoden administration were left to their discretion. The contract for the myoden administration was terminable and expired in a year or a few years. This was because kokuga tried to prevent tato fumyo from having a firm relationship with specific myoden. For above reasons, tato fumyo is regarded as a specialist of the myoden administration.
In the process of contracting out the myoden administration to tato fumyo by kokuga, the conditions, such as the rate and the item of taxation imposed on each myoden, became varied based on the situation in each area. This variation was a result of negotiation between tato fumyo and the then-current kokushi (provincial governors). Among the successors of such kokushi, however, some ignored the precedent agreements and collected the regular or an even greater amount of land tax. As a result, disputes between tato fumyo and kokushi became very common. Kokushi kasei joso, an appeal made by tato fumyo to the central government against lawless actions of kokushi, was the manifestation of the above situation and became conspicuous after the late tenth century.
In the eleventh century, tato fumyo became reluctant to administrate the myoden because it imposed the kanmotsu and the zoyaku as taxes on them. As a result, they deliberately devastated the myoden, and linked themselves to the great and powerful (dominant nobility or dominant temples and shrines) by becoming their yoriudo (a dependent, frequently one who served a noble house or proprietor) to embark on reclamation of the run-down fields with them. This reclamation of the run-down fields entailed expansion of shoen by the great and powerful. Therefore, the central government under FUJIWARA no Michinaga promulgated numerous acts to curb such activities but failed to stem the above mentioned tide.
The expansion of shoen meant the decline of revenue in the national finance. Therefore, since around the middle of eleventh century, the central government began to adopt realistic policies in order to secure its financial revenue. As part of such policies, bechimyo was officially recognized. The bechimyo was the system in which the central government put local lords including tato fumyo under a obligation to pay a certain amount of kanmotsu instead of admitting their domination over the area that was far more vast than myoden and included uncultivated lands, fields and mountains. The central government also eliminated arbitrariness of kokushi and enforced Koden kanmotsu rippo (the law fixing the tax rate of kanmotsu, tribute) to fix the tax rate of kanmotsu in every province. Although the cases of Kokushi kasei joso were decreased by the implementation of these policies, the expansion of shoen was not curbed enough due to the advent of zoyakumen (exception from all levies except the regular land tax) shoen or Kokumen sho (a shoen allowed exemption from so or other tribute in benpo or binho system) and so on.
From the beginning of the twelfth century, kokuga began to put in serious efforts to tackle the expansion of shoen. They reorganized Kokugaryo (territories governed by provincial government office) by dividing it into units of taxation, such as Gun (country), Go (village), Ho (district) and Jo (street), each of which had originally been the myoden or the bechimyo. In the organization of such Gun, Go, Ho, and Jo, the tato fumyo or the bechimyo contracted for the payment of land tax to the kokuga. However, the conventional contracting relationship for a limited period of time was highly unstable for the contractors like tato fumyo. Therefore, kokuga, who also needed to stabilize their income by the kanmotsu, came to approve the semi permanent relationship between tato fumyo and specific myoden. In this way, the tato fumyo class became capable of fixing their rights to specific myoden, and it helped tato fumyo to develop into myoshu (owner of rice fields).