Archive for August 13th, 2010

Related parties for transfer pricing purposes

August 13, 2010  |  Group Taxation, Transfer Pricing  |  No Comments

Foreign related parties - capital relationship

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