Support for mutual agreement procedures

In Japan, a total of 243 bilateral advance pricing agreement (BAPA) applications were filed from 1 July 2022 to 30 June 2023. 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.

When do you need to request mutual agreement procedures?:

When applying for a BAPA
When requesting relief for double taxation relating to transactions between Japan and another country (covered by an appropriate tax treaty)

PwC Tax Japan’s Transfer Pricing Team provides:

support for obtaining advance pricing agreements (APAs) and
support for requesting relief for double taxation relating to transactions between Japan and another country.

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Our team

Goro Mizushima

Partner, PwC Tax Japan

Takeki Nagafuji

Partner, PwC Tax Japan

Junko Yamato

Partner, PwC Tax Japan

Chihiro Takeuchi

Partner, PwC Tax Japan

Support for Local File preparation

Support for mutual agreement procedures

When do you need to request mutual agreement procedures?:

PwC Tax Japan’s Transfer Pricing Team provides:

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Our team

When do you need to request mutual agreement procedures?:

PwC Tax Japan’s Transfer Pricing Team provides:

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Our team

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