Archive for February 28th, 2011

Priority in Japanese transfer pricing methodologies

February 28, 2011  |  Transfer Pricing  |  No Comments

Flowchart showing priority among Japan's transfer pricing methodologies pre 2011 tax reform.

Japan’s 2011 tax reform proposals include the abolition of priority among the different approaches allowed under the transfer pricing regulations to price controlled transactions (‘TP Methodologies’). The proposals are intended to be effective from 1 October 2011 if passed by the Japanese Diet in early 2011.

This article introduces a flow chart outlining the priority in which different TP Methodologies should be applied. Read More

Transfer pricing and Japanese 2011 tax reform

February 28, 2011  |  Transfer Pricing  |  No Comments

An artfully composed photograph of recently planted rice fields in rural Japan.

The outline of 2011 Japanese tax reform proposals (link in Japanese) issued on the 16th of December 2010 include a number of technical changes to the Japanese transfer pricing regulations that have important practical implications for transfer pricing practice in Japan. This article summarizes those proposed changes.

The transfer pricing section of the 2011 tax reform proposals starts by noting that proposed changes to the transfer pricing regulations Read More