Cosmos International Management Co., Ltd.



News (November 5, 2010)


NTA announced statistics on international taxation (in Japan) for FY2009

As of November 4, 2010, the National Tax Agency announced gStatistics on Corporate Taxation for Fiscal Year 2009h, which includes gStatistics on International Taxationh as follows:

(1) Statistics on All Cross-Border Transactions (amount: 100 million YEN)


(2) Statistics on Anti-Tax Haven Taxation (amount: 100 million YEN)


(3) Statistics on Transfer Pricing Taxation (amount: 100 million YEN)


(4) Statistics on Advance Pricing Arrangements (gAPAh) with respect to Transfer Pricing Taxation


(Reference: National Tax Agencyfs website, except that the average tax adjustment amounts were calculated by Cosmos International Management)


For the taxation on all cross-border transactions, while the number of tax adjustments decreased, the amount of tax adjustments largely increased by approximately 3.6 times in Fiscal Year 2009 (from July 1, 2009 to June 30, 2010) from the previous fiscal year. The possible reason is an effect of IBM Japan's huge amount of tax adjustments, reported in March 2010.IBM Japan has been assesed over JPY40 million for five years. It may be the largest amount of tax adjustment and seems to have great impact on the amount.

For anti-tax haven taxation, both the number and the amount of tax adjustments increased from the previous fiscal year, particularly the amount was double . For tax adjustment amount on transfer pricing, while the number of tax adjustments decreased, the amount of tax adjustments increased again. In addition, the average tax adjustment amount on transfer pricing substantialy increased from JPY213 million of the previous fiscal year to JPY687 million.

For statistics on APA, the number of filed applications and concluded applications slightly increased from the previous fiscal year. The number of pending APA hit another highest record reaching 340 because the number of filed APA was 52 more than the number of concluded APA.


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