The Japanese tax authorities increasingly have been concerned with transfer pricing issues related to intangible assets as a result of the advanced globalization of business activities. Newspapers have reported cases where significant tax assessments have been made when the underlying disagreement with the tax authorities related to the value and location of intangible assets.
The Revised Transfer Pricing Administration Guideline and a collection of Case Studies have been published as additional guidance. The revised Guidelines give specific examples of intangible assets, which should be investigated in transfer pricing audits.
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Thursday, November 1, 2007
Japan Transfer Pricing Issues and Intangible Assets
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