PwC Transfer Pricing News

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2010

July

Key Amendments to the Commissioner’s Directive on the Operation of Transfer Pricing (Administrative Guidelines) [PDF 96KB]

Amendments to the Japanese transfer pricing law to reflect the 2010 Tax Reform were enacted on March 31, 2010. On June 22, 2010, further guidance on the Tax Reform was published by the National Tax Agency . This update summarizes the contents of this additional guidance.

April

Clarification of the Documents Required to be Presented or Submitted Pursuant to Paragraph 6 of Article 66-4 (Estimation Taxation Clause) [PDF 43KB]

The 2010 tax reform proposed certain clarifications to the requirements for documentation under the Japanese transfer pricing legislation, Special Taxation Measures Law Article 66-4 (“Article 66-4”).

2009

December

A Japanese Perspective on the OECD Proposed Revision to Chapters I-III of the Transfer Pricing Guidelines [PDF 44KB]

On September 9, 2009 the OECD released a proposed revision to Chapters I-III of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“Transfer Pricing Guidelines”).

August

Global Tax Highlights Vol 3
New Transfer Pricing Guideline in China and its Implications for Japanese MNEs (P26)

First Taxpayer Success in Japanese Transfer Pricing Litigation (P43)