AOA Seminar Understanding the Compliance Requirements of the AOA (for Non-Financial Institutions)


Session Closed

We are pleased to invite you to our seminar, which will discuss and explain the compliance requirements introduced into the Japanese tax law as a result of adopting the OECD’s authorized approach to the attribution of profit to permanent establishments (the “AOA”). This seminar will be useful to the finance / tax personnel of foreign corporations in Japan operating as a branch or other permanent establishment, particularly those in the non-financial services industry.

The AOA was introduced into the Japanese tax law for fiscal years beginning on or after 1 April 2016. As a result, taxpayers operating in a branch or other permanent establishment should have completed (March year end taxpayers) – or be in the middle of (e.g., December year end taxpayers) – their first year operating under the AOA.

It is therefore an appropriate time to review the requirements of the AOA, to ensure that taxpayers are complying with all aspects of the new law. This seminar is intended to provide guidance on the relevant issues, such as:

  • What is a “dealing” and how can they be recognized?
  • How is taxable income determined under the AOA, i.e., what does a P&L under the AOA look like?
  • What documents or evidence are required to support a dealing and the AOA P&L?
  • What is the impact of a bilateral treaty on dealings?
  • What are the withholding or other indirect tax implications of dealings?
  • What are the AOA reporting requirements?
  • How do the transfer pricing documentation rules apply to permanent establishments?
  • What impact will the AOA have on tax audit practice?

The seminar will be in English. If you would like to attend, please complete the online registration form. We look forward to seeing you.

Seminar Introduction

Date & Time

4:00pm - 6:00pm, Thursday, July 20, 2017
(Doors Open at 3:30pm.)

Place & Capacity


PwC Tax Japan
Kasumigaseki Bldg 14F, 3-2-5 Kasumigaseki, Chiyoda-ku Tokyo 100-6015 (MAP)

  • Registration may close early due to capacity.
  • We may ask companies with multiple attendees to adjust enrollments due to capacity and the objective of the seminar.
  • Kindly note that we do not accept registrations from employees of other professional services firms.


3.30 p.m.


4.05 p.m. – 4.55 p.m.

Implementation of the AOA (dealings, P&L, treaties)

4.55 p.m. – 5.05 p.m.


5.05 p.m. – 5.40 p.m.

Reporting requirements under the AOA (AOA and TP legislative requirements)

5.40 p.m. – 6.00 p.m. 



Ryann Thomas, Partner
Yoko Kawasaki, Partner
Ashlyn Kayoboke, Manager

The seminar will be in English.

Host Party

PwC Tax Japan


Free of Charge

Contact Information

PwC Tax Japan
Junko Ando Tel: 03-5251-2097

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