Japan's transfer pricing regulations put the onus on taxpayers to demonstrate that prices of all related party transactions are compliant with the arm’s length principle. Taxpayers should have transfer pricing policies and supporting documentation to reduce audit risk.

How can Grant Thornton Taiyo Tax Corporation help you?

Our transfer pricing advisory team can assist you with all aspects of implementing and managing a Japan-compliant transfer pricing policy, including:

  • Risk analysis – identify transfer pricing risks through an economic analysis of your business;
  • Documentation – prepare transfer pricing documentation or review existing documentation to ensure Japan compliance;
  • Benchmarking – provide industry-specific benchmarking studies against Japan or international companies;
  • Audit support – plan or review audit counter-measures, attend on-site audits, and assist in negotiations with NTA examiners;
  • APA applications – facilitate and assist the APA application process from initial planning and document preparation through final settlement;
  • MAP applications – facilitate and assist the MAP application process from preliminary meetings through mutual consultation requests, negotiation, and settlement.
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Grant Thornton Taiyo Tax Corporation periodically holds seminars providing practical information on transfer pricing issues faced by clients. Attending a seminar is free and presents an opportunity for consultation with our tax professionals. For more information about attending a seminar, please contact us.

Seminars / Consultations

Risk Assessment, Documentation and Benchmarking

Grant Thornton Japan can provide cost effective transfer pricing risk assessment and planning, TP documentation and benchmarking analysis.

Advanced Pricing Agreement (“APA”) Application

For some taxpayers, obtaining an APA may provide an effective solution to transfer pricing audit risk Our transfer pricing professionals can facilitate and provide support throughout the APA process:

Audit Support

Having an appropriate transfer pricing policy and supporting documentation in place is the most critical part of achieving a favorable audit result, or to reduce the risk of being selected for a full-scale transfer pricing audit.

Mutual Agreement Procedure (MAP) Applications

For taxpayers facing a transfer pricing assessment, our transfer pricing experts offer comprehensive support services for mutual agreement procedures (MAP).

Risk Assessment, Documentation and Benchmarking

Grant Thornton Japan can provide cost effective transfer pricing risk assessment and planning, TP documentation and benchmarking analysis.

Audit Support

Having an appropriate transfer pricing policy and supporting documentation in place is the most critical part of achieving a favorable audit result, or to reduce the risk of being selected for a full-scale transfer pricing audit.

Advanced Pricing Agreement (“APA”) Application

For some taxpayers, obtaining an APA may provide an effective solution to transfer pricing audit risk Our transfer pricing professionals can facilitate and provide support throughout the APA process:

Mutual Agreement Procedure (MAP) Applications

For taxpayers facing a transfer pricing assessment, our transfer pricing experts offer comprehensive support services for mutual agreement procedures (MAP).