Japanese transfer pricing legislation change to abolish hierarchy among transfer pricing methods and implement the ‘Most Appropriate Method’ rule, in alignment with the revised OECD Transfer Pricing Guidelines

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On June 30, 2011, a revision to the Japanese Transfer Pricing Legislation was promulgated to incorporate the rule of most appropriate transfer pricing method, in line with the 2010 revision to the OECD Transfer Pricing Guidelines ("OECD Guidelines"), and thereby abolish the hierarchy among the transfer pricing methods. This revision is applicable for accounting periods starting on or after October 1, 2011.