Overview of tax controversy procedures
Japan Inbound Tax & Legal Newsletter January 2019, No. 35
Companies and individuals that are required to file tax returns in Japan have options available to challenge a notice of assessment that the tax authorities (generally, the regional taxation bureau or tax office) issue as a result of a tax audit.
In a case where the tax authorities issue an assessment notice, the taxpayer may either accept the assessment or challenge it by filing a request for reexamination with the tax authorities that issued the assessment or a request for reconsideration with the Director-General of the National Tax Tribunal (NTT).
If the taxpayer requests a reexamination, but the tax authorities rule against the taxpayer and stand by the first assessment, the taxpayer still may file a request for reconsideration with the Director-General of the NTT.
In general, the taxpayer may bring a case to court only after the Director-General of the NTT renders an unfavorable decision in a request for reconsideration.
This newsletter explains the following topics;
1. Request for reexamination
2. Request for reconsideration
3. Filing a lawsuit
* This Article is based on the relevant Japanese or specific country’s tax law and other authorities in effect on the date of this Article. This Article would not be guaranteed updating if there are any changes in Japanese tax law, any other law, or interpretations by the courts or tax authorities thereof after the date of this Article.