Japan: Transfer pricing documentation rules, based on BEPS recommendations

The tax commission of the ruling coalition (the Liberal Democratic Party and New Komeito) on 10 December 2015 reached an agreement for a draft outline of tax reform proposals for 2016.

Among the items in the draft outline are proposals for transfer pricing documentation rules based on Action 13 (Transfer pricing and country-by-country reporting) of the OECD’s base erosion and profit shifting (BEPS) project.

The draft outline of tax reform proposals for 2016 in Japan thus includes rules for country-by-country reporting, as well rules for filing master file and local file (contemporaneous documentation). Also certain key terms are defined.

KPMG observation

The items in the draft outline of the tax reform proposals could differ and be modified when the tax reform proposals are officially released.

Read a December 2015 report [PDF 297 KB] prepared by the KPMG member firm in Japan: Draft Outline of the 2016 Tax Reform Proposals