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Article
Fact-finding is key to successful tax appeals
Japan Inbound Tax & Legal Newsletter January 2020, No.50
Traditionally, Japan is the country where tax controversy has been the least prevalent, although this trend may be changing. According to the most recent statistics, 3,104 tax appeals were initiated in the National Tax Tribunal (NTT) in FY 2018, which represents an increase of more than 50% over a four-year period (i.e. since FY 2014). This increase is due to the Japanese tax authorities issuing an increasing number of assessment notices and taxpayers appealing the notices rather than complying with them.
There were 216 successful tax appeals to the NTT in FY 2018. Those appeals indicate that fact-finding is key to successful tax appeals to the tribunal.
This newsletter explains these topics;
(1) Options to challenge assessment notices
(2) Tax controversy process
(3) Fact-finding is what tax appeals are all about
* 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.
(160KB, PDF)
Professionals
Jun Sawada
Deloitte Tohmatsu Tax Co. Partner
Hiroki Yamakawa
Deloitte Tohmatsu Tax Co. Senior Advisor
