In Japan, a total of 148 bilateral advance pricing agreement (BAPA) applications were filed from 1 July 2019 to 30 June 2020. The Japanese National Tax Agency holds negotiations with treaty partners multiple times a year. Depending on the nature of the case, the negotiation process can take upwards of a year. Both the number of BAPAs and the number of transfer pricing assessments for mutual agreement procedures (MAP) are on the rise, so the Japanese tax authorities have a strong incentive to implement solutions for taxpayers for resolving double taxation.
