6. Japan

Monetary threshold for LF preparation

​ Applicable if, in the previous fiscal year, transactions with a single foreign-related party were either:

• JPY 5 billion or more (excluding intangible assets), or

• JPY 300 million or more (only intangible assets)

Preparation deadline

• By the due date for filing the final tax return, which is within 2 months after the end of the fiscal year.

Submission deadline

• By the date specified by the tax authority (typically within 45 or 60 days of a request).

Language

• No specific language is required, but a Japanese translation may be requested by the tax authorities.

Penalty

• The tax authorities may determine taxable income based on estimated arm’s length prices using undisclosed comparables.

  • Reference: Article 66-4 of Act on Special Measures Concerning Taxation