Transfer Pricing


This page collates articles on transfer pricing. At this stage this site is only intending to cover some of the basic Japanese transfer pricing rules pending completion of the sections on corporate reoganisations. Please don’t hesitate to use the contact form to let me know if there are any areas you are interested in.

Priority in Japanese transfer pricing methodologies

Priority in Japanese transfer pricing methodologies

02/28/2011 • Japan’s 2011 tax reform proposals include the abolition of priority among the different approaches allowed under the transfer pricing regulations...Read More

Transfer pricing and Japanese 2011 tax reform

Transfer pricing and Japanese 2011 tax reform

02/28/2011 • The outline of 2011 Japanese tax reform proposals (link in Japanese) issued on the 16th of December 2010 include...Read More

A mini case-study in residual profit split transfer pricing

A mini case-study in residual profit split transfer pricing

11/03/2010 • A Tax Tribunal appeal case (the ‘Appeal’) reported on 28 June 2010 provides a useful ‘mini case study’ in the...Read More

Donations to foreign related parties

Donations to foreign related parties

08/15/2010 • This article examines an issue that often arises during the course of a corporate tax audit of the Japanese subsidiary...Read More

Related parties for transfer pricing purposes

Related parties for transfer pricing purposes

08/13/2010 • This article outlines the definition of Special Relationship and Foreign Related Party (‘FRP’) for Japanese transfer pricing purposes and includes...Read More

Tax Controversy - disallowance of related company recharges

Tax Controversy – disallowance of related company recharges

08/11/2010 • The Asahi Newspaper reported on 11 August 2010 that Hewlett Packard’s Japanese subsidiary (‘Japan HP’) had received an assessment in...Read More