Transfer Pricing

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• Transfer Pricing in Japan

• 
  Timo Singer

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  Transfer Pricing in Japan

  Dear all,
  
  In March I will start to work as a trainee for a German company in Japan. The department I will work for is responsible for the documentation of transfer prices. Especially for all Asian businesses.
  
  Did anybody had experiences with the Japanese law in Transfer Prices? How is it differing from the German law or the OECD Guideline?
  
  I am especially interested in:
  - The necessary amount of documentation
  - Solo attempts of the Japanese legislator
  - Are any services/businesses free of documentation
  - How are transfer pricing guidelines beeing accepted as evidence
  - Experiences from tax audits
  ...
  
  I would also be thankfull for some helpfull links.
  
  Regards,
  Timo
  
  • 11 Feb 2010, 6:30 pm
  Timo Singer wrote: > Dear all, > > In March I will start to work as a trainee for a German company in > Japan. The department I will work for is responsible for the > documentation of transfer prices. Especially for all Asian businesses. > > Did anybody had experiences with the Japanese law in Transfer Prices? > How is it differing from the German law or the OECD Guideline? > > I am especially interested in: > - The necessary amount of documentation > - Solo attempts of the Japanese legislator > - Are any services/businesses free of documentation > - How are transfer pricing guidelines beeing accepted as evidence > - Experiences from tax audits > ... > > I would also be thankfull for some helpfull links. > > Regards, > Timo
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• 
  Timo Singer

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  Re^2: Transfer Pricing in Japan

  Thank you Thomas, these links are quite helpfull.
  
  Regards,
  Timo
  
  • 14 Feb 2010, 10:06 am
  Timo Singer wrote: > Thank you Thomas, these links are quite helpfull. > > Regards, > Timo
• 
  Henning Straeter    Group moderator

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  Re^3: Transfer Pricing in Japan

  Dear Timo,
  
  please take a look to this link - it could be quite helpful
  
  http://www.kpmg.ch/docs/Global-Transfer-Pricing-Review.pdf
  
  PS. I made a lot of TP-Doc for JP (incl. IPs). If you have any question, please do not hesitate to contact me.
  
  Best regards,
  Henning Straeter
  
  • 21 Feb 2010, 11:24 am
  Henning Straeter wrote: > Dear Timo, > > please take a look to this link - it could be quite helpful > > http://www.kpmg.ch/docs/Global-Transfer-Pricing-Review.pdf > > PS. I made a lot of TP-Doc for JP (incl. IPs). If you have any > question, please do not hesitate to contact me. > > Best regards, > Henning Straeter
• 
  Luis Carrillo

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  Re^4: Transfer Pricing in Japan

  I recommend you take a look at IBFD's transfer pricing database. It has very detailed information on country-by-country TP legislation, acceptable methods and documentation requirements.
  
  As far as comparables, there is a strong preference for Japanese comparables in Japan (similar to Germany). Bureau van Dijk has excellent coverage of company data in Japan and Asia as a whole, and we have a product, TP Catalyst, which works with our databases to conduct transfer pricing analysis with links to IBFD. The product can be used in Japanese.
  
  • 21 Mar 2011, 7:38 pm
  Luis Carrillo wrote: > I recommend you take a look at IBFD's transfer pricing database. It > has very detailed information on country-by-country TP legislation, > acceptable methods and documentation requirements. > > As far as comparables, there is a strong preference for Japanese > comparables in Japan (similar to Germany). Bureau van Dijk has > excellent coverage of company data in Japan and Asia as a whole, and > we have a product, TP Catalyst, which works with our databases to > conduct transfer pricing analysis with links to IBFD. The product > can be used in Japanese.