PwC Transfer Pricing News

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2014

April

The Berry Ratio and Japan Transfer Pricing Practice [PDF 163KB]

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.

March

OECD releases discussion draft on transfer pricing documentation and country-by-country reporting [PDF 87KB]

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.

2013

May

A fresh look at the Japan-US bilateral APA relationship [PDF 157KB]

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).

February

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.

2012

June

NTA Transfer Pricing Update [PDF 114KB]

The NTA has introduced a survey to evaluate taxpayer efforts to manage their transfer pricing.

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)

2008

2007