Posts Tagged ‘donation’

Donations to foreign related parties

August 15, 2010  |  Domestic, Transfer Pricing  |  No Comments

Shishi odoshi, often seen in Japanese temples or traditional gardens

This article examines an issue that often arises during the course of a corporate tax audit of the Japanese subsidiary of a foreign multinational.  During such an audit the auditors may assert that a Japanese company’s transaction with its Foreign Related Party (‘FRP’) is a “Donation” for Japanese tax purposes (as defined below) Read More

Tax Controversy – disallowance of related company recharges

News, information

The Asahi Newspaper reported on 11 August 2010 that Hewlett Packard’s Japanese subsidiary (‘Japan HP’) had received an assessment in respect of JPY47Bn (USD550m) unreported income. Read More

Tax Controversy – Daiei taxed on forgiveness of debt to subsidiaries

July 31, 2010  |  Corporate Recovery, Developments, News  |  No Comments

News, information

Japanese retailer Daiei was assessed JPY25Bn (USD294m @85) for understating taxable income for four years.  The Asahi newspaper reported as follows: Read More