Cosmos International Management Co., Ltd.



News (November 9, 2011)


NTA announced statistics on international taxation (in Japan) for FY2010

As of November 2, 2011, the National Tax Agency announced gStatistics on Corporate Taxation for Fiscal Year 2010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 anti-tax haven taxation, although the number of tax adjustments increased from the previous fiscal year, the amount of tax adjustments was nearly a half of the previous fiscal year. This indicates an increase in the number of tax examination for small and medium-sized enterprises with relatively small amount of tax adjustments.

For transfer pricing, although the number of tax adjustments increased by 46%, the amount of tax adjustments increased only by 1.6%. This implies that tax examinations for large scale of transactions took a round and tax examinations and adjustments for smaller transactions have been increasing.

For statistics on APA, the number of filed applications decreased from the previous fiscal year, while concluded applications increased by 53% and surpassed the number of filed applications by 4, thus the number of pending APA decreased.


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