For the benefit of taxpayers in Japan for whom the Berry ratio may be unfamiliar, this article discusses its history and its potential uses, as well as comparing the results derived from an application of the Berry ratio with other transfer pricing methodologies.
This Transfer Pricing News provides a summary of discussion draft on transfer pricing documentation and country-by-country reporting released by Organisation for Economic Cooperation and Development (OECD) on 30 January 2014.
On March 26, 2013, the Internal Revenue Service of the United States issued its 14th Annual Statutory Report on Advance Pricing Agreements. The most interesting point of the report from the Japanese perspective is that 53% of bilateral APAs executed by the IRS in 2012 involved Japan as a counterparty (or 55 bilateral APAs in absolute numbers).
Update on audit procedures [PDF 142KB]
The revision of the Act on General Rules for National Taxes (clarification of audit procedures) and its impact on transfer pricing audits.
NTA Transfer Pricing Update [PDF 114KB]
The NTA has introduced a survey to evaluate taxpayer efforts to manage their transfer pricing.
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.
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”).
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”).
Osaka / Nagoya