Japan remains one of the most challenging tax jurisdictions, with transfer pricing enforcement being a focal point of the Japanese tax authorities. Both foreign and Japanese multinationals face increasing scrutiny and a heightened risk of transfer pricing audits and potential adjustments, explain Karl Gruendel and Rolf Heussner of Ernst & Young Shinnihon Tax.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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