Japan Tax Bulletin

The automatic exchange of Country by Country Reports (CbCR)

The 2016 Tax Reform introduced requirements for a Specified Multinational Enterprise Group to prepare a Country by Country Report (CbCR) and Master File, The documents need to be filed electronically with the NTA within one year of the end of the ultimate parent company’s fiscal year beginning after March 31, 2016. The NTA has to provide foreign competent authorities with the information within 6 months of the filing deadline (reduced to three months for the second reporting year onwards) and so has started providing the CbCRs they received to foreign competent authorities.

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