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Japan transfer pricing documentation guide

January 31, 2008

Ken Okawara, head of transfer pricing and economic analysis, Baker & McKenzie GJBJ Tokyo Aoyama Aoki Koma Law Office (Gaikokuho Joint Enterprise)

There is no definite legislative requirement regarding transfer pricing documentation under Japanese law, although for all practical purposes, taxpayers are expected to maintain documentation. Japan's Administrative Guidelines list 22 items of information to be reviewed during the transfer pricing audit, including the documents used to determine transfer prices as follows.




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