International Taxation
International taxation
General tax accountant firms rarely handle international tax cases due to knowledge and language issues, and the tax firms that can handle such cases are inevitably limited to major tax accounting firms, which tend to charge large fees for their services.
Our firm's experience working overseas and working for global companies enables us to provide services for cross-border transactions and tax reporting not only in Japan but also in other countries at a reasonable price.
Income tax returns for foreign assets and preparation of foreign assets statement
With globalization, the number of cases in which foreign assets are traded, held, and managed is increasing.
As a result, there are an increasing number of cases where income tax, inheritance tax, and gift tax returns on foreign assets are required.
In addition, in order to prevent taxpayers from failing to report their overseas property, a new system was established that requires taxpayers to directly provide information on their overseas properties.
We can assist you in filing tax returns for such overseas property.
Inheritance declaration of foreign property
The maximum inheritance and gift tax rate in Japan is 55%, and the rate is to increase in the future.
In particular, foreign property owned by residents of Japan may be subject to Japanese inheritance tax as well as foreign inheritance and estate taxes.
We can prepare for tax returns for inheritance and gift taxes, as well as provide support for overseas tax returns in relation to international inheritance.
Overseas tax consultation and tax filing
We have established a network of overseas tax specialists and can provide overseas tax consultation and tax filing services.
Supported countries
U.S.A.
France
China
Taiwan
Korea
Hong Kong
Singapore
Vietnam
Australia
Transfer pricing support
Local File Creation
We analyze transactions between the Japanese parent company and foreign related parties and detailed functions and risks, and prepare local files in line with the transfer pricing taxation system.
Procedures for Creating Local Files
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1. Fact Analysis
We analyze the facts such as Japanese parent company, the outline of the foreign affiliate, the capital relationship, the outline of the group, the internal organization chart, the profit and loss situation of each company, and the outline of the industry to which the company belongs. In addition, a commercial flow diagram will be created to determine the flow of transactions between affiliates, transaction amounts, and pricing policies.
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2. Functional and Risk Analysis
Analyze the functions and risks of the Japanese parent company and the foreign affiliate with respect to the transaction under analysis.
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3. Economic Analysis
Based on the results of the analysis, we determine the appropriate transfer pricing calculation method, select comparables, and calculate the appropriate profit margin range.
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4. Creation of local files
Document the contents of steps 1. through 3. as a local file to prepare for a transfer pricing audit in Japan.
Transfer Pricing Policy Development
Develop a transfer pricing policy to reduce the risk of transfer pricing taxation for the entire group in foreign related transactions.
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1. Preparation of a draft transfer pricing policy
For clients who have not yet prepared for transfer pricing documentation, we will obtain factual information such as an overview of the parent company and foreign affiliated parties and capital relationships, analyze detailed functions and risks, and prepare for a draft transfer pricing policy.
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2. Introduction of transfer pricing policy
Change the current terms and conditions of transactions, etc. to those in accordance with the transfer pricing policy.
APA and Mutual Agreement Procedure Support
Mutual Agreement Procedures are consultations between the Japanese tax authorities and the tax authorities of the other country under a tax treaty.Mutual Agreement Procedures are not possible with countries or regions that have not concluded tax treaties.
There are two types of mutual consultations: those conducted in response to taxation and to eliminate double taxation, and those pertaining to prior confirmation.
Advance Pricing Agreements (APA) can be bilateral (bilateral APAs) or multilateral (multilateral APAs), which require mutual consultation, or single country APAs (unilateral APAs), which do not require mutual consultation.A system under which the tax authority verifies and confirms the reasonableness of the transfer pricing calculation method, etc. proposed by the taxpayer to the tax authority.
We work with affiliated foreign experts to support APAs and mutual consultations.