Japan transfer pricing documentation guide
March 01, 2010
Ken Okawara, Yukiko Komori, Satoko Kawamura, and Koji Oshima of Baker & McKenzie GJBJ Tokyo Aoyama Aoki Koma Law Office (Gaikokuho Joint Enterprise) review the Japanese documentation situation.
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 Commissioner’s Directive on the Operation of Transfer pricing (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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