Japan's National Tax Agency has issued guidance on the country's new transfer pricing documentation requirements, which are in line with the three-tiered approach developed under Action 13 of the OECD BEPS Project. The main aspects of the guidance are summarized as follows.
Country-by-Country (CbC) Report
MNE groups operating in Japan must submit a CbC report when deemed to be a Specified MNE Group, which means the total revenue of the group in the Ultimate Parent Entity's preceding fiscal…