04 February 2016

Japan's 2016 tax reform includes Action 13 transfer pricing documentation requirements

Japan is an influential party in the Organization for Economic Co-operation and Development's (OECD) Base Erosion and Profit Shifting (BEPS) project and has made significant input into the final reports that were released October 5, 2015. The Japanese Ministry of Finance official has been the chair of the OECD's Committee on Fiscal Affairs, which is responsible for the OECD Transfer Pricing Guidelines. Japan is therefore expected to adopt many of the BEPS recommendations. Accordingly, Japan's 2016 tax reform includes the OECD's three tiered recommendations for transfer pricing documentation under Action 13 (country-by-country (CbC) report, master file, and local file).

A Tax Alert prepared by Ernst & Young Japan, and attached below, provides additional details.

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Document ID: 2016-0246