Tax Controversy Japan Update 2025

Tax controversy trends

1. Tax controversy trends

(1) Tax audits

According to the latest fiscal year (FY) 2024 statistics on tax audits (July 2023 through June 2024) published by Japan’s National Tax Agency, the number of field audits of corporate taxpayers in FY 2024 decreased by 5.4% from FY 2023, and the total amount of income found in FY 2024 increased by 24.9% from FY 2023. The total amount of corporation tax imposed by field audits in FY 2024 increased by 12.5%. These figures indicate that tax audit activities continued to be proactive in FY 2024, considering that such activities increased drastically in FY 2023.

The number of field audits on corporations for consumption tax in FY 2024 decreased by 6.0% from FY 2023, and the total amount of consumption tax imposed by field audits in FY 2024 decreased by 19.3%. Still, these figures indicate that consumption tax continued to be one of the major tax audit focal points in FY 2024, considering that those in FY 2023 increased drastically. In particular, the tax authorities conducted intensive tax audits of corporate taxpayers claiming a refund of consumption tax, conversely imposing JPY 39 billion on those taxpayers.

Please refer to our Tax Controversy Japan Updates 2025.

* 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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