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Japan amends transfer pricing guidelines

January 27, 2009

Japan’s National Tax Agency (NTA) has issued a series of amendments to its existing administrative guidelines on transfer pricing, as well as the accompanying reference case studies.

These amendments closely match proposed changes issued in June 2008. While many changes are narrow and technical, three areas are of special interest. The guidelines are an internal NTA document that is targeted at tax examiners rather than taxpayers. However, as the guidelines give far more extensive transfer pricing guidance than Japanese law or regulation, they serve as an important reference point for taxpayers.

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