Cosmos International Management Co., Ltd.

News (October 20, 2011)

NTA announced situation of mutual agreement procedure for FY2010

The National Tax Agency announced the Situation of Mutual Agreement Procedure (gMAPh) for its Fiscal Year 2010 (from July 1 2010 to June 30 2011). According to the announcement, the total number of filed MAP cases in FY2010 decreased to 157 compared with 183 in FY2009. On the other hand, the total number of settled MAPs in FY2010 recorded the highest 164 compared with 154 in FY 2009 and the number of settled cases surpassed filed cases. Also regarding MAP for Advance Pricing Arrangement (gAPAh), the number of filed cases decreased but the number of settled cases hit the highest. Over 90% of filed and settled MAPs are transfer pricing matters including APA.

The number of filed MAP cases in total decreased for the first time in 6 years. One of reasons for the result may be that the disastrous earthquake in eastern Japan in March forced companies to be occupied with emergency responses. However, MAP cases between OECD non-member countries have continuously increased. At present, China, India, and Southeast Asia are included in the category of OECD non-member countries. Although the percentage of cases with those non-member countries for MAP is still a few, it is gradually on the rise.

If regulations and system for MAPs and APAs in those non-member countries are more established, it is expected that the percentage of cases involving those non-member countries will be increasing further.


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