Cosmos International Management Co., Ltd.

News (November 29, 2010)

NTA announced situation of advance pricing arrangement with mutual agreement procedure for FY2009

As of November 24, the National Tax Agency announced the Situation of Advance Pricing Arrangement with Mutual Agreement Procedure (gMAPh) for its Fiscal Year 2009 (from July 1 2009 to June 30 2010). According to the announcement, the total number of filed and settled MAP cases in FY2009 recorded the highest, 183 compared with 174 in FY2008 and 154 compared with 127 in FY 2008 respectively.

176 (96%) of the 183 filed MAPs were for transfer pricing matters, and 149 were for APA. The number of filed APA with MAP has been hitting the highest for the five consecutive years.

138 (90%) of the total number of settled MAPs were for transfer pricing matters, and 105 for APA also has been hitting the highest. However the situation in which filed cases surpass settled cases consistently continues, and the total number of inventory MAPs also hit another record from FY2008fs 351 to 380. By the context of severe enforcement of the international taxation for transfer pricing by Japanese tax authority, the number of APA application to evade the risk increases, therefore the NTAfs continuing endeavor to settle more MAP cases would be desired.

The number of counter-party countries having ongoing MAPs was 21 as of the end of FY2009, (at the end of FY2008 year was 22), (Country details: Europe 11, Asia 7, Oceania 1 and North America 2). Of total 21 countries, 18 have ongoing APA-related MAPs with Japan.


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