Transfer Pricing -documentation requirement in Japan-

To adhere with the BEPS project, the 2016 Japan tax reforms, effective from 1 April 2016, requires multinational enterprise to submit three types of transfer pricing documents to tax authorities by e-tax if the annual consolidated group revenue over Yen 100 billion in the preceding year.

(1)Notification for Ultimate Parent Entity;

(2)Country-by-Country report; and

(3) a master file; and

In addition “Local file” must be prepared and presented within 45 days after tax authority requested in the tax audit. Local file is not required to be prepared if:

-the amount of transaction to one of the group is less than Yen 5 bil nor amount of intangible asset transaction to one of the group is less than Yen 300mil.