Tax Controversy Japan Update 2023

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 trends

1. Tax controversy trends
(1) Tax audits

According to the latest fiscal year (FY) 2022 statistics on tax audits (July 2021 through June 2022) published by Japan’s National Tax Agency, the number of field audits of corporate taxpayers in FY 2022 increased by 63.2% from FY 2021, and the total amount of income found in FY 2022 increased by 14% from FY 2021. The total amount of corporation tax imposed by field audits in FY 2022 increased by 19.1%. These increases indicate that tax audit activities were expanding in FY 2022.The number of field audits on corporations for consumption tax in FY 2022 increased by 62.9% from FY 2021, and the total amount of consumption tax imposed by field audits in FY 2022 increased by 19.1%, which indicates that consumption tax was one of the major tax audit focal points in FY 2022. In particular, the tax authorities conducted intensive tax audits of corporate taxpayers claiming a refund of consumption tax, conversely imposing JPY 37 billion on those taxpayers.

Please refer to our Tax Controversy Japan Updates 2023.


* 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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