07 April 2016

Japan implements Authorized OECD Approach for determination of transfer pricing for PEs

The Authorized Organisation for Economic Co-operation and Development (OECD) Approach (AOA) for the determination of transfer pricing for permanent establishments (PEs) in Japan is now in effect in the Japanese legislation for fiscal years beginning on or after April 1, 2016. All companies with PEs in Japan need to make the transition to the new approach and also consider whether an Advanced Pricing Agreement (APA) is warranted given the increased risks brought about through changes in pricing.

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

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ATTACHMENT

Full text of Tax Alert 2016-0633

Document ID: 2016-0633