The major reform of Transfer pricing documentation rules was made in 2016 and the relevant law and legulation were changed. This reform was made as a response to Organisation for Economic Co-operation and Development (OECD) Base erosion and profit shifting (BEPS) Action Plan 13. The National Tax Agency issued four guidelines, as shown below, that provide concrete explanations and practical examples related to this reform for the members of multinational enterprise in Japan.
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