Tax Controversy Japan Updates

This article provides an overview of areas of focus and the tax audit and controversy procedure in relation to national tax (excluding customs duty) in Japan.

Tax Controversy Japan Updates 2019

Recent areas of focus

(1) Transfer pricing

In line with the OECD BEPS project, the Japanese tax authorities increasingly are focusing on transfer pricing audits. The scope of general corporate tax audits now typically includes transfer pricing, with both regional tax bureaus and local tax offices actively examining transfer pricing matters. A transfer pricing audit may be undertaken even if the taxpayer files an application for an advance pricing arrangement.

Please refer to our Tax Controversy Japan Updates 2019.


* 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.

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