Updates on transfer pricing and international tax, decarbonisation and sustainability, and accounting and tax, with comments from the principal. Filter by date or search by keyword.
NEWS
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Other accounting & tax
National Tax Agency Public Notice No. 26 (Partial Amendment to the Public Notice Designating Vending Machines Pursuant to Article 18-2, Paragraph 2, Item 3 of the Order for Enforcement of the Consumption Tax Act)
The public notice designating vending machines that may be used for tax-exemption sales procedures under the tax-free shop system (yushutsu buppin hanbaijo, i.e., licensed sites for the sale of export goods) has been amended. Clients that operate tax-free shops are advised to check whether their equipment is covered. (https://www.nta.go.jp/law/kokuji/r0811/01.htm)
Transfer pricing
NTA Updates List of "Jurisdictions Implementing Automatic Exchange of Country-by-Country Reports with Japan"
The National Tax Agency has updated its list of countries and jurisdictions that automatically exchange Country-by-Country Reports (CbCR) of multinational enterprise groups with Japan. Because the list affects whether a local filing (secondary filing) obligation arises for a Japanese subsidiary, clients with overseas parent companies should check whether their parent's jurisdiction is covered. (https://www.nta.go.jp/taxes/shiraberu/kokusai/eoi/pdf/001.pdf)
Decarbonisation & sustainability management
METI Signs Joint Declaration of Intent on Clean Hydrogen with Germany’s Federal Ministry for Economic Affairs and Energy
The declaration was signed by Parliamentary Vice-Minister of Economy, Trade and Industry Miyamoto and German Parliamentary State Secretary Rouenhoff during German Chancellor Merz’s visit to Japan. It covers the entire clean hydrogen value chain, from production through trade, transport, storage, distribution and use. The two sides will cooperate in seven areas: market and demand creation, international trade and supply chains, infrastructure, investment, regulation and certification, research and development, and business-to-business collaboration. Japan hopes to use the agreement to expand hydrogen supply-demand and supply-chain cooperation with Europe. (https://www.meti.go.jp/press/2026/10/20261029007.html)
Decarbonisation & sustainability management
Ministry of the Environment Opens Public Comment on Draft FY2026 LD-Tech List and Level Table
The Ministry of the Environment (MOE) has opened a public comment period on its draft FY2026 LD-Tech (Leading Decarbonization Technology) List and draft Level Table. The LD-Tech Level Table sets out performance benchmarks for high-efficiency equipment by category, and has been used as an eligibility requirement for subsidy programs and as a reference standard for equipment selection. It is worth checking at the draft stage whether equipment your company plans to replace falls within the covered categories and meets the specified levels. (https://www.env.go.jp/press/press_05710.html)
Other
Our website has been renewed
We have renewed our website today. The main changes are a new FAQ page, information on our accounting and tax advisory services (including example fees), expanded descriptions of our transfer pricing support and our decarbonisation and sustainability management advisory, and the latest news on the home page. We will continue to share clear and useful information. Thank you for your continued support.
Transfer pricing
Country-by-Country Reporting (CbCR): Compilation of 2026 Peer Review Reports (OECD, published October 19, 2026)
This publication compiles the results of the ninth annual peer review under the BEPS Action 13 minimum standard. Covering 142 jurisdictions, it assesses three areas: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of CbC reports. It is a useful resource for checking how each country is implementing transfer pricing documentation (CbCR). Notable points in individual countries’ responses are as follows. France has taken steps to improve the consistency of its CbCR regime with other international tax rules, and has been refining its administrative practices to ensure the accuracy of reported information. Singapore stands out for the expansion of its international information exchange network. As a regional hub in Asia, it continues to advance its alignment with global standards. The United Arab Emirates (UAE) has strengthened its anti-BEPS framework alongside its recently introduced corporate tax regime, and is accelerating its efforts to enhance international transparency. Japan continues to administer its regime in line with OECD standards. The review confirmed that its information exchange arrangements and domestic legislation are being operated broadly appropriately. Overall, the 2026 review shows that in many countries the focus has shifted from introducing the regime to improving its operation. Common themes include “efficiency through digitalization,” “strengthening international information exchange arrangements,” and “alignment with global minimum taxation.” (https://www.oecd.org/content/dam/oecd/en/publications/reports/2026/10/country-by-country-reporting-compilation-of-2026-peer-review-reports_d4c39c0d/353cb719-en.pdf)
International tax (other than transfer pricing)
NTA Publishes List of Jurisdictions Participating in the Automatic Exchange of GloBE Information Returns (GIR) with Japan
The National Tax Agency (NTA) has published a list of countries and jurisdictions that will automatically exchange GloBE Information Returns (GIR) under the Global Minimum Tax (Pillar Two) with Japan. As of October 1, 2026, 25 countries and jurisdictions are covered, including the United Kingdom, the Netherlands, Australia, South Korea, Switzerland, and Hong Kong, while exchange with Slovakia is one-way, with information provided by Japan only. For GIRs relating to fiscal years ending on or before March 31, 2025, the deadline for Japan's first exchange is March 31, 2027. As the number of jurisdictions with which automatic exchange is scheduled remains limited, groups should consider in advance how to handle GIR filing obligations in jurisdictions not covered by the automatic exchange arrangements. (https://www.nta.go.jp/taxes/shiraberu/kokusai/eoi/pdf/0026007-035.pdf)
Decarbonisation & sustainability management
Ministry of the Environment Publishes Outcome Report on International Meetings on Building Carbon Markets under AZEC
The report summarizes discussions at the AZEC Carbon Market Dialogue, co-hosted by the Ministry of the Environment and the Ministry of Economy, Trade and Industry (held online in April and June 2026, and in person in Hiroshima in July). Partner countries are making progress on GHG accounting and reporting systems and on corporate disclosure. Their approaches to carbon pricing, however, vary from country to country, including emissions trading, carbon taxes, and baseline-and-credit schemes. Participants agreed on a policy of developing markets alongside expanding private investment. Credit markets are developing through domestic schemes such as the J-Credit Scheme and through Article 6 of the Paris Agreement (including the JCM). The discussions emphasized several issues, the soundness of calculation methodologies, such as emission factors, conservativeness and environmental integrity, market infrastructure, such as registries and MRV, the credibility of credits. In light of this, the following points appear worth noting, ensuring the reliability of GHG emissions data will become even more important, practical guidance on the accounting treatment of carbon credits may be developed, emission allowances and carbon prices may begin to affect cost accounting and as carbon credits come to be traded internationally, international tax issues may arise. (https://www.env.go.jp/press/press_05654.html)
Decarbonisation & sustainability management
FSA Publishes Exposure Draft on “Revisions to the Auditing Standards”: Enhancing the Going Concern Assessment (Including Physical Climate Risks)
The Auditing Committee of the Business Accounting Council has published an exposure draft of revisions to the Auditing Standards and opened it for public comment. The revisions align Japan’s standards with the international standard on going concern, the IAASB’s revised ISA 570. Under the proposal, the assessment period would begin on the date the financial statements are approved, not at the fiscal year-end. For listed companies where a material uncertainty has been identified, the auditor’s report would also need to describe how the auditor evaluated management’s assessment. The IAASB’s revisions cover a broad range of events and conditions, including war, social unrest, pandemics, and physical climate risks. The revised standards would apply to audits of financial statements for fiscal years ending March 2028, and the comment period closes at 5:00 p.m. on November 16. Going concern disclosures now also take ESG-related physical risks into account, which is a clear sign of how times are changing. Going forward, companies should consider how non-financial risks of this kind, not just financial ones, may affect the going concern assumption. (https://www.fsa.go.jp/news/r8/sonota/20261016-2/20261016.html)
Decarbonisation & sustainability management
Ministry of the Environment Opens Second Call for Applications for Perovskite Solar Cell Deployment Support Program; First Call Deadline Extended
The second call for applications for the “Equipment Installation Program” opened on October 15. The program covers film-type perovskite solar cells, with requirements including installation sites with a floor load capacity of roughly 10 kg/m² or less, a minimum of 5 kW per facility, and proximity to the point of demand with a self-consumption rate of at least 50%. Local governments, private companies, and organizations are eligible to apply. The first-round deadline is October 30, and the final deadline is 12:00 noon on November 20 (applications must arrive by then). In addition, the deadline for the first call for applications for the “Preliminary Survey and Deployment Planning Program” has been extended from 12:00 noon on October 15 to 12:00 noon on November 20 (applications are reviewed on a rolling basis). The program is administered by the Association of Environmental Technology Promotion, a general incorporated association. (Equipment Installation Program (Second Call) / Preliminary Survey and Deployment Planning Program (Deadline Extension))
Decarbonisation & sustainability management
Ministry of the Environment Opens Second Call for Applications for FY2026 “Advanced Resource Circulation Investment Promotion Project”
The Ministry of the Environment has opened a second call for applications for subsidies that support installing equipment at business sites in Japan. The call covers two categories: resource circulation equipment for hard-to-abate industries, where cutting emissions is especially difficult, and recycling equipment that supplies the high-quality recycled materials needed for GX (green transformation) products. The implementing organization is the Japan Waste Research Foundation (JWRF), and application documents must arrive by noon on Friday, November 6. Companies that held back capital investment projects during the first call now have a chance to reconsider them. (https://www.env.go.jp/press/press_05661.html)
Decarbonisation & sustainability management
Ministry of the Environment Launches “Japan Accelerator Network” with WEF, Public-Private Forum on October 22
The Ministry of the Environment is launching Japan’s first environment-focused edition of the World Economic Forum’s (WEF) public-private Accelerator Network. To mark the launch, it will hold a hybrid event, the “Co-Creation Session on Decarbonized and Circular Community Development,” on Thursday, October 22, from 13:00 to 15:00. The participating companies are Kanadevia, LIXIL, Daikin Industries, Taiheiyo Cement, Tokyo Gas, and Mitsubishi Electric. The program includes a WEF presentation of case studies from other countries, presentations by each company, and a panel discussion. (https://www.env.go.jp/press/press_05685.html)
Decarbonisation & sustainability management
Ministry of the Environment to Hold 13th Meeting of GHG Calculation Methodology Review Committee on Oct. 15 — Treatment of Synthetic Fuels and CCS on the Agenda
The 13th meeting of the Review Committee on Calculation Methodologies under Japan's Mandatory Greenhouse Gas Emissions Accounting, Reporting and Disclosure System will be held online (streamed on YouTube) on Thursday, October 15, from 10:00 to 12:00 JST. Two items are on the agenda: "approaches to supply chain management for synthetic fuels, etc." and "the treatment of CCS." Meeting materials are scheduled to be released on the day, making this a session that offers an early look at where the calculation rules are heading. (https://www.env.go.jp/press/press_05669.html)
Decarbonisation & sustainability management
JAL, Toyota, and Nine Other Companies Join METI's Clean Fuel Certificate System Demonstration Project
On October 8, 2026, Japan Airlines (JAL) announced its participation in the Clean Fuel Certificate System Demonstration Project organized by the Agency for Natural Resources and Energy of Japan's Ministry of Economy, Trade and Industry (METI), together with nine companies including NTT DOCOMO, ENEOS, Kajima Corporation, and Shimizu Corporation. The program aims to create tradable environmental value certificates for next-generation fuels such as Sustainable Aviation Fuel (SAF) and Hydrotreated Vegetable Oil (HVO), enabling companies to exchange these environmental attributes in the marketplace. This mechanism allows fuel users to advance their decarbonization efforts without being constrained by the need for dedicated fuel infrastructure or geographic limitations in fuel procurement. Under the demonstration project, ENEOS will be responsible for importing HVO and providing the associated environmental value certificates, while participating companies, including JAL, will evaluate practical applications of the certificates and identify operational challenges within the system. Looking ahead, the initiative is expected to support corporate decarbonization strategies and potentially align with domestic and international greenhouse gas emissions management frameworks. Through this demonstration, stakeholders aim to accumulate knowledge regarding the effectiveness and implementation challenges of the system, contributing to the wider adoption of next-generation fuels and the realization of a carbon-neutral society. （https://press.jal.co.jp/ja/release/202610/009756.html）
Other accounting & tax
National Tax Agency Updates Special Website on Consumption Tax Rate Reduction
A detailed explanatory video (approximately 28 minutes) has been added to the special website on the “Two-Year Consumption Tax Rate Reduction for Food and Beverages,” based on the Cabinet decision of September 15. It can be viewed together with the existing overview video (approximately 2 minutes and 30 seconds), leaflet, Q&A, and call center information. Please note that the information on the website is based on the assumption that the bill will be passed and enacted by the Diet. (https://www.google.com/url?q=https://www.nta.go.jp/taxes/shiraberu/zeimokubetsu/shohi/keigenzeiritsu/zeiritsuhikisage.htm&source=gmail&ust=1791413604372000&sa=E)
Decarbonisation & sustainability management
Ministry of the Environment Announces Selected Projects for Plastic Resource Circulation Demonstration Program
On October 5, 2026, Japan's Ministry of the Environment announced the results of its public call for proposals under the FY2026 Decarbonized Circular Economy System Development Promotion Project (Plastic and Other Resource Circulation System Demonstration Project). The program aims to support the transition from fossil fuel-derived plastics to renewable resources and promote the practical application of advanced plastic recycling technologies as part of Japan's efforts to achieve a decarbonized society. The call for proposals was conducted between April and May 2026, and following a review process, two projects were selected. The chosen projects are: (1) a demonstration project by iPEACE223 Co., Ltd. focused on decarbonizing plastic feedstocks through the production of high-yield monomers derived from bioethanol, and (2) a material development project by GSI Creos Corporation aimed at utilizing recycled plastics in electrical equipment materials. Based on the fundamental principles of the Plastic Resource Circulation Strategy, known as “3R + Renewable,” the Ministry of the Environment is promoting the wider adoption of bioplastics and the advancement of recycling processes. Through this initiative, the ministry seeks to achieve both a circular economy and progress toward carbon neutrality.（https://www.env.go.jp/press/press_05646.html）
Decarbonisation & sustainability management
Ministry of the Environment Establishes the "Japan GHG Center"
Ministry of the Environment press release, October 1, 2026. The "Japan GHG Center," which will centrally collect and disseminate greenhouse gas observation data and scientific findings, was established on October 1. The National Institute for Environmental Studies (NIES), the University of Tokyo, Hiroshima University, the Japan Agency for Marine-Earth Science and Technology (JAMSTEC), the Meteorological Research Institute, and the Japan Aerospace Exploration Agency (JAXA) are participating. The center is positioned as an "All-Japan information hub" that brings together data such as atmospheric CO2 and methane observations from the GOSAT series of satellites. By strengthening coordination among the participating organizations, it aims to help accelerate climate change measures. (https://www.env.go.jp/press/press_05602.html)
Decarbonisation & sustainability management
Ministry of the Environment Announces Qualifications Certified Under the "Decarbonization Advisor Certification System"
Ministry of the Environment press release, October 1, 2026. The Ministry of the Environment has announced the qualifications newly certified under this system, through which the national government certifies private-sector decarbonization-related qualifications. Certification is divided into three tiers according to level of expertise: "Basic," "Advanced," and "Senior Advisor." In this round, "Carbon Accounting Advisor Level 1" (Carbon Accounting Advisor Association, a general incorporated association) was certified at the Senior Advisor level, and "GX Human Resource Development Seminar" (Value Frontier Co., Ltd.) was certified at the Advanced level. Certification is valid for two years from the date of certification, and a renewal procedure is in place. (https://www.env.go.jp/press/press_05621.html)
Decarbonisation & sustainability management
Ministry of the Environment Announces Nationwide Patrols Related to the Construction Recycling Act
On September 30, 2026, the Ministry of the Environment announced that it will conduct nationwide patrols related to the Construction Recycling Act, aimed at ensuring proper on-site waste separation during demolition, thorough promotion of recycling, prevention of asbestos dispersion, and appropriate recovery of fluorocarbons. The patrols are scheduled to take place from October to November 2026. As a result, stronger on-site guidance and monitoring will likely be required within the construction industry. In recent years, demolition work has become increasingly sophisticated—particularly regarding asbestos and fluorocarbon handling—raising the difficulty of legal compliance. At the same time, the government has entered a phase of further strengthening recycling rates, preventing illegal dumping, and ensuring safety. Currently, although administrative guidance is frequent, serious violations are rare, and the industry’s compliance is being steadily improved through corrective guidance. (https://www.env.go.jp/press/press_05630.html)
Decarbonisation & sustainability management
The Ministry of the Environment Announces the Transition of “Deco-Katsu” to Its Second Stage and Unveils the New Concept: “Making Decarbonization Easier — Raku Deco-Katsu”
On September 28, 2026, the Ministry of the Environment announced that its ongoing “Deco-Katsu” initiative will shift to the second stage, titled “Making Decarbonization Easier — Raku Deco-Katsu.” As key focus areas, the Ministry highlighted “clothing” and “housing (insulation).” In the clothing sector, the Ministry plans to launch a collaboration with the J.League, installing clothing collection boxes at match venues. In the housing (insulation) sector, DECA!BEAT, a project unit composed of members from Hello! Project, will promote insulation-related actions through videos and social media outreach. Since 2022, the Ministry has been promoting “Deco-Katsu,” with more than 4,000 companies and organizations participating in public–private collaboration. The second stage aims to further integrate “Deco-Katsu” into people’s everyday lives. (https://www.env.go.jp/press/press_05618.html)
Decarbonisation & sustainability management
Ministry of the Environment Announces Selected Projects for the FY2026 “Synergy-Based JCM Creation Project” under the Joint Crediting Mechanism (JCM)
On September 24, 2026, the Ministry of the Environment announced the selection of two projects under the Synergy-Based JCM Creation Project of the Joint Crediting Mechanism (JCM). ◆Sumitomo Corporation’s project, “Energy-Saving Project to Reduce Regenerative Power Loss on LRT Line 1”, and ◆Shibata Shoji Co., Ltd.’s project, “Demonstration Project for High-Efficiency AI-Controlled Air Conditioning Systems, Proper Refrigerant Treatment, and Metal Resource Recovery at BMA Hospital.” (https://www.env.go.jp/press/press_05484.html). This initiative is a subsidy program aimed at further promoting the JCM by supporting demonstration projects that introduce advanced decarbonization technologies in JCM partner countries where no JCM projects have been implemented to date. Going forward, the program seeks to foster “synergy-based” projects that simultaneously address social issues such as decarbonization, traffic congestion, and circular economy challenges. Small and medium-sized enterprises may also be eligible to apply for subsidies by conducting demonstration projects of decarbonization technologies in collaboration with overseas offices or international partners. By utilizing subsidies at the demonstration stage to test technologies and achieve measurable results, companies may later become eligible for equipment subsidies that enable larger-scale investments. In addition, as major corporations undertake overseas projects of this nature, opportunities may increase for small and medium-sized enterprises to provide related technologies and services—such as air-conditioning system installation, refrigerant recovery and treatment, waste management and resource recovery, and support for implementing AI-based control systems. If you have any questions regarding this matter, please feel free to contact our office.
Decarbonisation & sustainability management
METI Designates the First Round of GX Strategic Regions
On September 11, 2026, the Ministry of Economy, Trade and Industry (METI) designated 18 regions as the first round of GX Strategic Regions. This announcement matters because it shows which specific regions the national government will prioritize for support in building a GX industrial structure. Regions were selected nationwide, particularly under the "data center cluster" and "decarbonized power utilization" types, clarifying the future direction of industrial location policy. The GX Strategy is the Japanese government's national strategy for Green Transformation (GX). It aims to shift an economy and society centered on fossil fuels toward one that achieves both decarbonization and economic growth. A key feature is that it treats climate action as a growth opportunity rather than a cost. Designated regions benefit from government support for industrial cluster development, including capital investment support, power grid improvements, and regulatory reform. They may also receive the GX Regional Co-Creation Subsidy (subject to screening). We believe small and medium-sized businesses should also pay attention to the following points regarding the GX Strategy. ◆Whether your company is located in a GX Strategic Region. ◆Taking stock of capital investments that may be eligible for subsidies. ◆Monitoring the investment plans of large companies, and preparing to capture the surrounding demand created as large companies move into GX Strategic Regions. If you have any questions, please feel free to contact our office.
Decarbonisation & sustainability management
Morgan Stanley Released "Sustainable Reality" Report for the First Half of 2026
According to the first-half 2026 edition of "Sustainable Reality," a report published by major U.S. financial firm Morgan Stanley that analyzes global ESG investment trends, assets under management in ESG funds reached a record high, and their performance also outpaced that of traditional funds. These findings show that a growing number of investors and financial institutions are prioritizing sustainability. They also suggest that sustainability-conscious management and disclosure can give companies an advantage when raising capital from investors and financial institutions. In addition, the report finds that sustainable funds carry lower downside risk than traditional funds, suggesting that sustainability-focused management contributes to stable long-term growth and reduced risk. We expect that not only large corporations but also small and medium-sized enterprises will increasingly take steps such as: ◆Strengthening ESG disclosure by clearly communicating their environmental, social, and governance initiatives on their corporate websites and in IR materials. ◆Reviewing their business portfolios, for example by considering withdrawal from businesses with a high environmental impact or investing in new sustainable businesses. ◆Obtaining green certifications, ISO 14001, and similar credentials. ◆Clarifying their sustainability policies and targets in preparation for dialogue with financial institutions and investors. If you have any questions, please feel free to contact our office. (Source: https://www.morganstanley.com/content/dam/msdotcom/en/assets/pdfs/SustainableReality1H26MorganStanley.pdf)
Transfer pricing
Regarding the OECD's Proposed Revision of Chapter VII of the Transfer Pricing Guidelines: Intra-Group Services
I would like to share some thoughts on the draft revisions to Chapter 7 of the OECD Transfer Pricing Guidelines, “Intra-Group Services,” which the OECD released on June 1, 2026, as I found them noteworthy. The main proposed revisions and their potential impact are as follows. Many of the items appear likely to increase the administrative burden on taxpayers, which is an area of concern. ◆ The introduction of “Accurate Delineation” will require a stricter delineation of transactions based on their actual substance; ◆ the burden of applying the benefits test (which is separate from benchmark analysis) will increase; ◆ pricing methods will be expanded (meaning that a cost-based method will not necessarily be the most appropriate method by default); ◆ the distinction between shareholder activities (not chargeable) and stewardship activities (which may be chargeable) will be clarified; and ◆ new documentation guidance specific to services will be introduced, subject to certain conditions. Although the draft revisions have not yet been finalized, the OECD appears to be focusing not only on the resulting allocation of income from intra-group service transactions, but also on the actual substance and process of the transactions. This may be a good opportunity to review and reassess current intra-group service arrangements. Please feel free to contact us if you have any questions.
Transfer pricing
Revision of the Basic Corporation Tax Circular regarding the Special Documentation and Record Retention Requirements for Related-Party Transactions.
As discussed in our recent newsletter regarding the Special Rules for the Preparation and Retention of Documents Relating to Related-Party Transactions, the National Tax Agency (NTA) published the “Partial Amendments to the Basic Corporation Tax Circular and Related Administrative Guidance (Interpretive Circular)” on June 30, 2026 (Joint Circular No. Ka-ho 2-9 and others, dated June 30, 2026). The principal amendments are as follows. ◆Clarification of the definitions of related-party transactions, the scope of industrial property rights and similar intangible assets, and specific examples of service transactions. ◆Clarification that, for recurring and continuous transactions, a single Specified Information Document may be used provided that there are no changes to the underlying transaction terms or conditions. ◆Clarification that where the required information can be confirmed from multiple existing documents, it is not necessary to obtain or prepare an additional Specified Information Document. Our firm can also assist your organization in preparing, organizing, and retaining documentation relating to related-party transactions. Please feel free to contact us for further information.
Transfer pricing
Publication of Administrative Guidelines on the Basic Policy and Practical Treatment for Applying the Special Provisions on the Organization and Retention of Documents for Related-Party Transactions
On June 30, 2026, the National Tax Agency published administrative guidelines concerning the special provisions for the retention of documents related to transactions between related parties, with the aim of ensuring proper enforcement while reducing the administrative burden on taxpayers.The above special provisions for document retention (hereinafter referred to as the “Special Provisions”) require the preparation and maintenance of explanatory documents because, in intra-group transactions, it is often difficult for third parties to ascertain the details of transactions and the basis for calculating consideration, making it more difficult to clarify the actual circumstances.The key points of the administrative guidelines published this time are as follows:◆ The guidelines are not intended to uniformly require excessively detailed materials; rather, it is considered sufficient if the information can be objectively understood by a third party.◆ If the required information is sufficiently described in the transfer pricing documentation (local file), application of the Special Provisions is not necessary.◆ The retention of documents stating specified matters — in other words, documents that supplement insufficient descriptions — is not a requirement for deductible expense treatment. Instead, the determination is made after ascertaining the actual circumstances based on books and records, etc.◆ In principle, the place of retention of the documents is deemed to be the tax payment place, etc. of the domestic corporation. However, even if the documents are centrally managed by a parent company or similar entity, they will be treated as being retained if there is a system in place that enables them to be obtained and presented without delay.◆ If the documents are not retained or are insufficient, the tax examiner will specify a reasonable period and request the acquisition, preparation, and presentation of documents stating specified matters.◆ The obligation to retain documents stating specified matters is included in the book and document retention requirements for blue return filing. If retention is insufficient, there is also a possibility that the application of the net operating loss carryforward deduction may not be allowed.◆ The Special Provisions also apply to corporations other than blue return filing corporations.◆ If it is difficult to ascertain the actual amount due to the status of document retention, estimated taxation may be considered.
Other
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