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Tax (Transfer Pricing) Audit Defense and Mutual Agreement Procedure in Japan

The most effective and efficient tax audit defenses include early involvement of an experienced global team that has successfully resolved examinations at all possible levels of the process.

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Tax audit defense / MAP in Japan

During a tax authority examination or audit, the actions and responses from the very beginning of the process are important for the overall outcome of the process. It is important that proper explanations are provided to the tax authorities in response to enquiries or during interviews, for example explanation of the business and how the transfer pricing policies fit within this. The most effective and efficient defenses include early involvement of an experienced global team that has successfully resolved examinations at all possible levels of the process, from proposed adjustments by field auditors, through administrative appeals, litigation and the MAP/CA process.

Deloitte has extensive experience in assisting clients with tax authority examinations, audits, appeals, and MAP/CA which can be leveraged in order to ensure the efficient management of the entire process. We take an integrated approach to resolving transfer pricing disputes in the MAP/CA process. Our teams include transfer pricing MAP/CA specialists from both of the relevant countries teamed with professionals who specialize in local country requirements for indirect taxes, taxes imposed by local or state jurisdictions, international tax and interest calculations for late payment that invariably affect the outcome.