Japanese transfer pricing regulations and enforcement have undergone significant changes in the past few years. Historically, Japanese transfer pricing was a bit of a mystery to corporate taxpayers, because the transfer pricing law was so brief and because of the paucity of guidance in the administrative circulars. Taxpayers with related-party transactions involving Japan could not be sure of the best approaches to take in determining their own transfer-pricing policies and the best ways to prepare for possible audits. Anecdotal accounts of "secret comparable" audits (to be described in more detail below) made many taxpayers nervous, but the frequency of such audits and the difficulties taxpayers faced in such audits were not clear to those who had not experienced such audits themselves.
In just the past four years, however, significant revisions and expansions in the regulations (including the release of new administrative guidelines as well as expansions to existing circulars) have made Japanese transfer pricing more transparent and understandable to taxpayers, and the country is gradually conforming to international standards in its approaches and requirements. However, there remain differences between Japan and other OECD countries in the way the transfer-pricing rules are administered, and it is unclear the extent to which certain changes (such as the introduction of the transactional net margin method, an OECD-sanctioned pricing method recognized in many countries) will really be reflected in the approaches employed by transfer pricing examiners in the field.
This article attempts to provide an overview of Japanese transfer pricing rules and administration as of mid-2004. It begins with a summary of the Japanese transfer-pricing law and regulations. This is followed by descriptions of the current enforcement environment and the country's advance pricing arrangement (APA) programme. The article concludes with some suggestions for taxpayers with significant related-party transactions.
Basic regulations
Statutory provisions and additional guidance
The law governing transfer pricing is found in the Special Taxation Measures Law (STML) article 66-4, enacted in 1986. The STML establishes the arm's-length principle in Japanese tax law and defines the authority of tax examiners to restate taxpayers' transfer prices when cross-border related-party transactions are found not to have been conducted at arm's-length prices. (The law does not apply to transactions conducted between related parties within Japan.) The law provides a broad outline of the governing principles of Japan's transfer-pricing rules and permissible transfer-pricing methodologies. Further guidance is contained in several circulars, cabinet orders and administrative guidelines. STML Enforcement Order article 39-12 (Cabinet Order 39-12), most recently revised in April 2004, contains additional information on the definition of related-party transactions, permitted transfer-pricing methodologies, and other items. The STML Circular article 66-4, revised in September 2000, provides guidance regarding comparable transactions and important comparability factors, the application of the profit-split method, and the treatment of transfer pricing for transactions other than inventory transactions (for example, transactions of intangible assets and services). Administrative guidelines (Concerning the Establishment of Instructions for the Administration of Transfer Pricing Matters (the Administrative Guidelines)) released in June 2001 provide information about the conduct of transfer-pricing examinations, information to be requested in an examination, the treatment of intercompany services and intangible transactions, and Japan's APA programme.
Finally, one other circular with relevance for transfer pricing is the Commissioner's Directive on Mutual Agreement Procedures, released in June 2001. This circular contains guidance on filing procedures and required information for mutual agreement procedures regarding, among other things, transfer-pricing assessments and bilateral or multilateral APAs.
Definition of related parties
The Japanese rules state that two corporations are considered related parties subject to the transfer-pricing rules when one corporation owns 50% or more of the shares of the other corporation (Cabinet Order 39-12 paragraph 1). This 50% ownership can be direct or indirect. The Japanese rules also contain a test for "control in substance" for cases where two corporations do not meet the 50% ownership threshold but where one corporation may influence the other's business policies in other ways (Cabinet Order 39-12 paragraph 1(iii)).
Transactional approach
The Japanese rules state that "transactions" conducted with related parties should be conducted at arm's-length prices (STML article 66-4 paragraph 1), and the Japanese National Tax Agency (NTA) has interpreted this to mean that related-party transactions must be examined on a transaction-by-transaction basis, thus discouraging aggregation of transactions when analyzing transfer prices or overall profitability. Interestingly, the law states that transfer prices will only be modified by the tax authority when they are found to be above the arm's-length price in the case of prices paid to overseas related parties and below the arm's-length price in the case of prices received from overseas related parties. Together with the NTA's negative stance toward aggregation of transactions, this means that in many cases higher-margin transactions of taxpayers will not be allowed to offset lower-margin transactions when a taxpayer's transfer pricing is under examination. Thus a taxpayer could be reasonably profitable on an overall basis but still be subject to transfer-pricing adjustments on certain transactions. The rules do allow aggregation of transactions under certain circumstances (STML Circular article 66-4 paragraph 3-1), but the general preference of the NTA is for transactional analysis.
Permitted transfer pricing methodologies
The methodologies accepted in Japan are generally consistent with those recognized in the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the OECD Guidelines). The Japanese rules state a preference for the three traditional transaction methods: comparable uncontrolled price (CUP), resale price (RP), and cost plus (CP). These methods involve either a direct comparison of prices between a comparable transaction and a transaction of the taxpayer (in the case of the CUP method) or a comparison of gross profit margins or gross profit mark-ups earned in comparable transactions and those earned in the taxpayer's transactions (in the case of the RP and CP methods). When these methods are inapplicable, the law allows taxpayers to apply either methods "similar to" the three transaction methods or other methods defined by Cabinet Order (STML article 66-4 paragraph 2). The methods defined by Cabinet Order include the profit-split method (either the residual profit split or a profit-split based on a contribution approach, that is, a profit split which allocates combined profits in proportion to some factor such as total costs or fixed assets of the taxpayers involved in the related-party transactions under consideration) and the transactional net margin method (TNMM) (Cabinet Order 39-12 paragraph 8). The TNMM, which compares the operating profit margins or net mark-up over total costs of comparable transactions to those of the taxpayer, was only recently recognized in Japan and is permitted only for fiscal years beginning on or after April 1 2004.
The above methods apply in the case of tangible inventory transactions. For all other transactions, the rules state that methods "equivalent" to those permitted for tangible transactions may be used (STML article 66-4 paragraph 2(ii)).
Documentation requirements
Although Japan requires taxpayers to make certain disclosures regarding their intercompany transactions in their corporate tax returns (described in greater detail below), there are no explicit requirements for contemporaneous documentation. The rules strongly suggest, however, that taxpayers are expected to have documentation available to the NTA in the event of a transfer-pricing examination. For example, the Administrative Guidelines contain an extensive list of the types of documents that might be requested in an examination (Administrative Guidelines paragraph 2-4), including the following:
documents describing the capital relationships between the taxpayer and its foreign related parties;
documents describing the taxpayer's intercompany transactions in detail;
documents describing the business activities, products, and financial performance of the taxpayer and its related parties;
documents which the taxpayer used to compute its arm's-length prices, including transfer-pricing studies, descriptions of comparable transactions and their selection process, and explanations of any adjustments made to account for differences between the tested party and the comparables;
other documents including accounting manuals, descriptions of transfer-pricing examinations or APAs of the taxpayer's foreign related parties, and transfer-pricing documentation prepared by the foreign related parties; and
other documents which the transfer-pricing examiners "recognize to be necessary"
There are no specific penalties for failure to produce documentation. However, there is a strong, indirect incentive for taxpayers to prepare and maintain documentation, as the failure to do so may lead transfer-pricing examiners to resort to the use of secret comparables.
As mentioned above, taxpayers are required to disclose certain information about their intercompany transactions in schedule 17-3 attached to their corporate tax return. This information includes names and addresses of related parties with which the taxpayer transacted, types of intercompany transaction conducted (for example, inventory transactions, intangible transactions, financial transactions and service transactions), financial performance of the related parties, and the newly-imposed requirement to disclose the transfer-pricing methodology used for each type of intercompany transaction (that is, CUP, RP, CP or other methods). This latter requirement, effective for tax years beginning on or after April 1 2003, signals the NTA's expectation that taxpayers have clearly defined transfer-pricing policies supported with sufficient documentation and analysis.
Intangible transactions and intercompany services
The Japanese transfer-pricing regulations provide only limited guidance for determining arm's-length prices for transactions involving intangible property. The rules state that methods "equivalent to" those used for tangible transactions should be applied to intangible transactions (STML article 66-4 paragraph 2(ii)). They note that any comparable transactions used (for example, in a CUP analysis) should involve the same kinds of intangible property and similar transactional conditions to those of the taxpayer's tested transaction (STML Circular article 66-4 paragraph 5-6).
Similar to the rules for intangible transactions, the regulatory guidance for intercompany services historically has been limited. In June 2002, however, Japan expanded the rules for intercompany service transactions with an addition to the Administrative Guidelines defining intercompany services in greater detail and providing additional guidance as to what types of services require the computation of arm's-length remuneration. In short, any service provided to a related party which the recipient would have purchased from an unrelated party or performed for itself in the absence of the service from the related party requires the computation of arm's-length prices. The Administrative Guidelines list the types of services requiring arm's-length remuneration. Among them are accounting and tax services, information system management, cash flow management, assistance with manufacturing or distribution, and training of employees (Administrative Guidelines paragraph 2-10).
Similar to intangible transactions, service transactions are to be tested using methods "equivalent to" the methods permitted for tangible transactions (STML article 66-4 paragraph 2(ii)). The rules note that the CUP and CP methods will often apply, and they state that services provided in comparable transactions and the conditions of the provision of those comparable services should be similar to those of the tested transaction (STML Circular article 66-4 paragraph 5-5).
Advance pricing arrangements
APAs, which allow taxpayers to negotiate with the NTA in advance of related-party transactions to obtain the NTA's agreement on the appropriate transfer-pricing methodology and results, have been available to taxpayers in Japan since 1987. Over the years, Japan's APA programme has undergone significant changes and has become a popular means for taxpayers with significant intercompany transactions to obtain greater certainty regarding their transfer pricing. Additional detail on Japan's APA programme is provided under the heading "Advance Pricing Arrangements" below.
Enforcement environment
Number of assessments, transfer pricing personnel
Transfer-pricing enforcement remains quite active in Japan, with the NTA continuing to issue frequent and sizeable assessments. In the administrative year from July 1 2002 to June 30 2003 (referred to in this section as 2002), the NTA issued 62 transfer-pricing adjustments to taxpayers' income, the highest number since 1997. The total amount of income adjustments in that year was ¥72.5 billion ($659.6 million), down somewhat from 2001's total of ¥85.7 billion ($779.7 million), but higher than in the years 1998 to 2000.
Also in 2002, the Tokyo Regional Taxation Bureau had 24 senior transfer-pricing examiners (in addition to the supervisors and heads of each group within the transfer-pricing section). Typically, each senior examiner is paired with a junior transfer-pricing examiner for each examination or APA review. The Osaka Regional Taxation Bureau had eight senior transfer-pricing examiners. Other regional taxation bureaux do not have staff dedicated exclusively to transfer pricing but have international taxation examiners with knowledge of transfer pricing.
Secret comparables
Historically, Japanese transfer-pricing enforcement has been characterized by the occasional use of "secret comparables" by transfer-pricing examiners in computing tax assessments.
Secret comparables are transactions carried out by undisclosed third parties and used by the examiners for comparison with a taxpayer's intercompany transactions. Examiners are authorized under certain circumstances to visit third-party comparables to collect data on the profitability of certain transactions or business segments. This transactional profit data is, of course, confidential business information, and the examiners are forbidden by law from disclosing confidential information to others, even to the taxpayer under examination for transfer pricing. Therefore, when the examiners compute an assessment using secret comparables, they will not disclose any identifying information on the comparables to the taxpayer. This, of course, makes it extremely difficult for the taxpayer to determine the comparability of the selected transactions and to rebut the examiners' analysis. Understandably, many taxpayers find the use of secret comparables highly objectionable, as there is no way to verify the accuracy or reasonableness of the examiners' conclusions.
The examiners' authority to use secret comparables is contained in a provision of the law which states that examiners may visit third parties to collect information (for example, business and transactional information) when taxpayers have failed to provide, in a timely manner, information requested by the examiners and deemed necessary for the computation of arm's-length prices (STML article 66-4 paragraph 9). This carries significant implications in any discussion of Japan's documentation requirements, because even though Japan has no explicit penalties for failure to maintain documentation, there is the significant risk that failure to provide transfer-pricing documentation requested during an examination (including documentation that was prepared contemporaneously) will trigger the use of secret comparables.
Public statements by Japanese tax officials in recent years have implied that Japan is reducing its use of secret comparables and limiting them only to cases when examiners are "forced" to use them by taxpayers that do not provide sufficient information for the calculation of arm's-length prices. It is clear, however, that the NTA still considers secret comparables to be one of its enforcement tools in administering the transfer-pricing rules. As recently as April 2004, a high-ranking NTA official has commented that secret comparables may still be used when taxpayers fail to respond to information requests in a timely manner. He added, however, that when examiners use secret comparables, they will provide explanation (to the extent possible without compromising the secret comparable's confidentiality, of course) of the selection criteria, content of the transactions, and adjustments made to account for differences between the comparables and the taxpayer.
Introduction of transactional net margin method
The TNMM has been introduced recently in Japan and is available to taxpayers for fiscal years beginning on or after April 1 2004 (Cabinet Order 39-12 paragraph 8). The introduction of the TNMM brings Japan's transfer-pricing rules closer to the OECD Guidelines and the rules of many other countries.
At first glance, the availability of the TNMM may seem advantageous for taxpayers, particularly for taxpayers who use the TNMM in other countries but have been forced to consider other methods in Japan due to the lack of the TNMM in the Japanese rules. To be sure, there are certain advantages to the introduction of the TNMM in Japan. In identifying comparable transactions for use in a TNMM analysis, standards of comparability are generally more relaxed than in a traditional RP or CP analysis, because the TNMM examines operating profit margin levels which are usually less sensitive to differences in function (such differences often being reflected in selling, general and administrative expense (SG&A)) than gross margins (which measure the profit earned before SG&A expense).
The focus on operating margins in a TNMM approach also eliminates difficulties associated with differences between the taxpayer and comparables in classification of expenses between cost-of-goods-sold and SG&A (which can affect gross margin in a RP or CP analysis). Moreover, the introduction of the TNMM should also make bilateral competent authority negotiations (for both double taxation cases and APAs) between Japan and its treaty partners easier, because Japan now shares this method with many other tax jurisdictions.
It is unclear, however, the extent to which transfer-pricing examiners in the field will actually be willing to accept TNMM analysis in practice. According to the new rules, the TNMM is given lower priority than the three traditional transaction methods. Examiners could therefore reject the TNMM in a variety of circumstances, arguing that one of the three traditional transaction methods is applicable in a particular taxpayer's case and should therefore be used instead of the TNMM. Even in cases where the examiners agree that TNMM is applicable, they may have views on comparability that differ from those of most taxpayers. As mentioned above, one of the advantages of TNMM is that standards of comparability are generally more relaxed than in a RP or CP analysis. In Japan, however, examiners have been known to place more emphasis on product and transactional comparability than other tax administrations, and the same may be true even for cases where TNMM is applicable. In other words, broad comparability of functions and business activities may not be sufficient to satisfy the examiners' requirements for comparability.
It is also true that the recognition of the TNMM provides examiners with another tool in testing taxpayers' transfer pricing. It is conceivable that examiners may use the TNMM to compute transfer-pricing assessments in cases where the traditional transaction methods would not lead to such assessments.
Only after the first round of examinations under the new rules will it begin to become clear how examiners will use the TNMM in practice.
Current and future targets for enforcement
It is always difficult to predict the kinds of transactions and taxpayers that will be subjected to particular scrutiny for transfer pricing, but a few items are clear.
Firstly, the NTA has signalled its intent to scrutinize intercompany service transactions. The introduction of the new service regulations in 2002 was a result of the NTA's desire to examine in greater detail the various activities conducted by Japanese-headquartered companies for their overseas affiliates. The NTA wants to ensure that Japanese taxpayers are adequately remunerated for the benefits that their service activities provide to their affiliates.
Secondly, there are indications that the NTA will devote increased attention to commissionaire pricing arrangements. Under a commissionaire arrangement, a taxpayer outside Japan establishes a subsidiary in Japan to perform selling activities for the foreign taxpayer's products. The subsidiary does not take title to any products or record trade sales to customers, however. The foreign taxpayer, who is the principal in the commissionaire arrangement, sells its products directly to Japanese customers and pays a commission to the subsidiary for its selling activity.
Disputing an assessment
There are several avenues of domestic appeals available to taxpayers who have received a transfer pricing assessment. In addition, for assessments related to transactions with a country that has a tax treaty with Japan, taxpayers in many cases can invoke the mutual agreement procedure described in the treaty and request negotiations between Japan and the treaty partner. The two tax administrations will then endeavour to reach agreement on a transfer-pricing methodology to resolve the double taxation arising from the assessment.
The domestic appeals procedures consist of administrative appeals and litigation. There are two steps in the administrative appeals process.
Firstly, within two months after receipt of the assessment notice, a taxpayer may file a request for re-examination with the regional taxation bureau that issued the assessment. If a decision is not reached on this request within three months after the request is filed, the taxpayer may file a request for reconsideration with the National Tax Tribunal, a quasi-judicial organ within the NTA. Taxpayers with "blue return" status, which carries various privileges such as depreciation deductions, tax-free reserves and loss carryover, may proceed directly to the National Tax Tribunal without first filing a request for re-examination with the regional taxation bureau. Such a request must be filed within two months following the date of the assessment notice.
If the taxpayer's request for reconsideration is dismissed, or if the National Tax Tribunal does not reach a decision within three months after the filing of the request for reconsideration, the taxpayer may file a lawsuit with the district court.
In general, tax assessments in Japan are rarely reversed on appeal. Many taxpayers who have received transfer-pricing assessments for transactions with a treaty partner country therefore opt to file for a mutual agreement procedure. This is particularly effective in resolving double taxation when the overseas tax administration is one with which Japan has had a long relationship and history of negotiations (such as the US, Australia and certain European countries).
It is possible to file simultaneously for domestic appeals and a mutual agreement procedure. Because mutual agreement procedures are usually more effective, however, many taxpayers who have filed for both will request that the domestic appeal proceeding be suspended until the mutual agreement procedure is concluded. If the two tax authorities involved are able to reach agreement, the taxpayer can withdraw the appeal; if not, the taxpayer can pursue the appeal.
Advance pricing arrangements
APAs have been available to taxpayers in Japan since 1987. Initially, there was little guidance available to taxpayers about APA procedures and policies, but in recent years the NTA has released detailed rules and descriptions of the APA process. Japan's APA programme is currently quite well-developed and increasingly popular with taxpayers.
The Administrative Guidelines contain detailed explanations of APA procedures and the information required from taxpayers (Administrative Guidelines chapter 5). In September 2003, the NTA also released its first report on the Japanese APA programme, the APA Program Report, which describes various features of the Japanese APA programme, including the programme's history, procedures, and requirements. The report also describes key statistics of Japan's APA programme, such as the number of cases filed and resolved and the number of APAs by industry and transaction type.
The rising popularity of Japan's APA programme is demonstrated by the increase in APA filings over the last several years. For example, the number of bilateral APA cases received by the government in the 2000 through 2002 period was 137, while only 121 cases were received during the entire period from 1987 through 1999. The number of bilateral cases "disposed" (including cases in which the taxpayer and NTA reached agreement and cases in which the taxpayer withdrew the application) in 2000-2002 was 101, compared to 69 in the 1987-1999 period.
Taxpayers who desire an APA in Japan must be prepared to file numerous documents and undergo a review process that can take anywhere from six months to two or more years.
Documents required with an initial APA filing include:
descriptions of a taxpayer's intercompany transactions;
descriptions of the taxpayer's relationships with its related parties;
details of the taxpayer's proposed transfer-pricing methodology;
analysis demonstrating the result when the proposed transfer-pricing methodology is applied to the past three fiscal years;
explanation of functions performed by the taxpayer and its related parties;
description of any transfer-pricing examinations or appeals underway in the country with which the relevant transactions are conducted; and
the taxpayer's critical assumptions (that is, important features of the taxpayer, its business, and economic conditions, the continuation of which are necessary for the APA to remain in force) (Administrative Guidelines paragraph 5-2).
Taxpayers who request an APA must first undergo a review process by the regional taxation bureau with jurisdiction over the taxpayer. This process typically requires between six months and one year. In the case of a unilateral APA (that is, filed only in Japan), final approval of the APA is granted shortly after the regional taxation bureau reaches its conclusions and has those conclusions approved by the NTA examination division. In the case of a bilateral APA (that is, an APA negotiation involving not only the taxpayer and the NTA but also one or more overseas tax administrations with a stake in the transactions covered by the APA), the domestic review is followed by a negotiation among the relevant tax administrations in accordance with the mutual agreement procedure defined in the tax treaty between Japan and the other tax administration(s). This negotiation can require between six months and three years. Therefore, from initial filing to final agreement, a bilateral APA can require between one and four years.
In principle, APAs in Japan cover three prospective tax years, although taxpayers can request longer periods such as five years. Taxpayers can also request retroactive application of APA terms to prior tax years.
There are several advantages to filing an APA. One well-known advantage is that an APA is generally friendlier than an examination. In an APA, the taxpayer proactively presents its case to the NTA and solicits feedback, rather than reacting to questions and assertions of examiners intent on uncovering problems. APAs also provide taxpayers with an opportunity to explain special circumstances or business conditions that may have affected their profitability. (In an examination, there is usually less time to present and discuss such explanations, and examiners may be less willing to consider such arguments in the adversarial atmosphere of an examination.) In a bilateral APA, taxpayers can also rely on the opposing tax administration of the treaty partner country to impose some restraint on the NTA, reducing the likelihood of a result that would leave excessive profits in Japan.
Need to be ready
Japan still conducts rigorous enforcement of its transfer-pricing rules and has one of the most well-developed systems of transfer-pricing regulations and administration in the world. The gradual convergence of Japanese rules to international standards is good news for taxpayers who have previously found Japan's approaches difficult to reconcile with accepted approaches in other countries.
Considering the NTA's continued aggressive enforcement activity for transfer pricing, taxpayers with significant intercompany transactions should, at a minimum, prepare basic documentation demonstrating, through the application of methodologies approved in Japan, that their transfer pricing is in compliance with the Japanese rules. This will enable taxpayers to make appropriate disclosures on the aforementioned schedule 17-3 of their tax returns and should provide a certain minimum level of support in the event of an audit.
Taxpayers in particularly risky situations (for example, taxpayers experiencing fluctuating profits or operating losses, taxpayers with significant transactions with tax havens, or taxpayers with higher risk transaction structures such as commissionaires or limited risk distributor subsidiaries) need to go beyond this basic level of preparation and prepare detailed documentation describing their transactions, analytical approaches, and reasons why their selected methodologies and conclusions are appropriate for their business. The documentation should attempt to anticipate and respond to any objections that might be raised by the NTA in an examination. In some instances, high-risk taxpayers may want to consider filing for an APA to forestall an audit and obtain certainty over the approach that will be accepted by the NTA.
As always, the amount of preparation required depends on each taxpayer's particular circumstances and transactions. Given the NTA's continued focus on transfer pricing, however, all taxpayers with significant intercompany transactions need to prepare some form of transfer-pricing analysis to determine their overall risk level and to demonstrate their compliance with the rules in the event of a transfer-pricing examination.
Biographies |
|||||||||
Karl Gruendel is a manager in the Tokyo office of Ernst & Young. He has conducted economic analysis to evaluate the transfer pricing of a wide range of clients. He has performed studies of transfers of tangible inventories, licensing of intangible property, intercompany provision of services, global trading of financial instruments, and other transaction types. He has assisted clients in such industries as software, medical devices, chemicals, electronics, and financial services. Gruendel has also represented clients in various discussions with the Japanese tax authorities. He has defended companies under audit, assisted companies in their negotiation with the tax authorities to obtain advance pricing arrangements, and has served as a liaison between clients and the tax authorities during competent authority discussions.
Ken Okawara is a partner in Ernst & Young's Tokyo office where he heads the firm's Japanese transfer pricing practice. He has published several books and many articles on transfer pricing and international tax issues in Japan and overseas. He is a frequent speaker on international transfer pricing and tax issues at various seminars in Japan and other countries. He teaches international tax at Gakushuin University as a lecturer. He is also a research affiliate at Columbia University Graduate School of Business Center on Japanese economy and business. Ken has assisted numerous multinational companies in their negotiations with the tax authorities of Japan and other countries and has helped clients to obtain resolution of transfer pricing disputes at bilateral and multilateral competent authority proceedings. He has been involved in more than 30 advance pricing arrangement cases covering Japan, the US, the UK, Switzerland, Australia, Singapore, Korea and China.
Mark Campbell is a tax partner in Ernst & Young's Tokyo office where he works in the transfer pricing and cross-border corporate tax areas. Mark worked in US tax before transferring to Tokyo in 1992. While in Japan, he has worked with a wide variety of international clients in connection with their transfer pricing and international tax matters. He has published a variety of articles and reports on transfer pricing and international tax issues. At Ernst & Young Japan, he is responsible for the Japanese transfer pricing issues of foreign companies investing in Japan. |
