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Proposed amendments to Japanese transfer pricing guidelines

September 29, 2008

Chris Newman and Jon Jenni from Ernst & Young Shinnihon Tax, Tokyo describe possible changes to Japan’s transfer pricing legislation

Japan’s National Tax Agency (NTA) issued proposed amendments to existing transfer pricing rules on June 5 2008. These proposed changes would affect multiple parts of the NTA’s administrative guidelines on transfer pricing as well as the accompanying reference case studies. The final amendments are expected to be released later in 2008. While many changes are likely to be narrow and technical, taxpayers should look for significant changes in the following three areas:

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