Posts Tagged ‘tax audits’

Audits of Japanese Corporate Reorganizations.

August 28, 2011  |  Developments, News  |  No Comments

News, information

In recent months the Japanese specialist tax press has reported on the increasing number of Japanese tax audits focusing on Japanese tax preferred corporate reorganizations (below “Japanese TPCRs’) . Please see the corporate reorganization section for details Read More

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