Transfer Pricing - Japan Compliance

Japan Compliance

Transfer Pricing

A collection of 3 posts

Summary of Japan tax-treaty dividend holding-period rules, 2022 Tokyo District Court ruling, and compliance checklist for U.S. multinationals

Dividend Withholding in Japan: Do You Meet the 6-Month Treaty Holding-Period Rule?

TL;DR * Japan’s bilateral tax treaties can slash dividend withholding tax, but parent companies must often meet strict share-holding-period tests. * A 2022 Tokyo District Court case on the Japan–Luxembourg treaty shows how Japanese courts calculate the six-month period—looking to the end of the subsidiary’s fiscal year,

Slide mapping Japan’s Pillar Two rollout: 15 % global minimum tax timeline, IIR calculation flow, CbCR safe-harbor tests and compliance checklist for MNEs.

Japan Embraces Pillar Two: Understanding the New Global Minimum Tax Rules and Their Impact on Multinationals

TL;DR * Japan implements the OECD Pillar Two 15 % global minimum tax from fiscal years starting 1 Apr 2024 via a stand-alone Income Inclusion Rule (IIR). * Top-up tax applies to MNE groups with €750 m+ revenue; Japan follows OECD GloBE mechanics, offers CbCR safe harbors through 2026, and will add

Slide mapping Japan’s international tax risks: PE thresholds, TP documentation, CFC inclusion tests, Pillar Two top-up tax timeline and mitigation checklist.

International Tax Risks in Japan: PE, Transfer Pricing, CFC & Pillar Two Guide for US Companies

TL;DR * Japan poses four headline risks for US multinationals: Permanent Establishment, Transfer Pricing, CFC rules and BEPS Pillar Two top-up taxes. * Mis-steps can push effective tax rates above 35 % or trigger double taxation. * Careful structuring, robust TP documentation and early modelling of Pillar Two exposures are essential. Table of