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Tokyo |
The number of mutual agreement procedures (MAP) involving an advance pricing agreement (APA) in Japan has increased by 600% in the last decade.
This is the message from the Japanese Tax Agency's annual report. The report says that 90% of all MAPs are related to transfer pricing issues.
As for cases on transfer pricing, increasing numbers of cases involve an APA. In the year from July 2005 to June 2006, 129 MAPs were agreed, of which 119 cases were related to transfer pricing and 92 involving APA for transfer pricing.
Compared to 10 years ago, the number of cases on MAP has increased about fourfold, while cases on MAP involving APA have also increased roughly sixfold.
