Japan has seen many changes in its approach to taxing corporate groups in recent years with the introduction of consolidated taxation, group-reorganization rules and in 2010 rules allowing deferral of taxation on certain intra-group transactions.
The Japanese corporate law has also seen significant reform in this period, Read More
This article outlines the definition of Special Relationship and Foreign Related Party (‘FRP’) for Japanese transfer pricing purposes and includes diagrams giving examples of the application of the definition. Transactions with an FRP with whom a Japanese company has a Special Relationship are subject to Japanese transfer pricing regulations and must be carried out at arms’ length to avoid tax adjustment. Read More
The diagram to the right in this post outlines two group relationships defined for Japanese corporate tax purposes. These are the Japanese Consolidated Tax group, that allows offset of losses within the Japanese group, and the IGTS group, that allows the transfer if assets between Japanese corporate members of the group without giving rise to gain or loss. Read More