Dispute resolution

Japan Dispute Resolution Country Profile



last updated 21 July 2015


Competent Authority

Administration of DTA
Deputy Commissioner (International Affairs) / National Tax Agency
3-1-1 Kasumigaseki, Chiyoda-ku, Tokyo 100-8978
Tel. +81-3-3593-6388, Fax. +81-3-3581-8627

Interpretation of DTA
Director-General / Tax Bureau / Ministry of Finance
3-1-1, Kasumigaseki, Chiyoda-ku, Tokyo 100-8940
Tel. +81-3-3581-3035, Fax. +81-3-5251-2120 


Office of Mutual Agreement Procedure in the National Tax Agency

Scope of MAP & MAP APA

Relief of taxation not in accordance with tax treaties, such as double taxation.

Domestic guidelines & administrative arrangements

MAP (Commissioner’s Directive on MAP, June 25, 2001 (last updated on March 31, 2015)

APA (Section 5 of Commissioner’s Directive on the Operation of Transfer Pricing, June 1, 2001) (last updated on June 28, 2013) 

Time for filing

MAP: some tax treaties have provisions on time limits

APA: by the commencing date of the first taxable year

Form of request

MAP: form named “Application for the Mutual Agreement Procedure”

APA: form named “Request for APA of the Transfer Pricing Methodology”

Documentation requirement

MAP: Commissioner’s Directive on MAP, Sec. 6(1), 11, 12, 29

APA: Commissioner’s Directive on the Operation of Transfer Pricing, Sec. 5-3, 5-4, 5-11(3), 5-17, 5-20, 5-22, 5-24, 5-25(3)

User fees


Tax collection / penalty / interest

Suspension of collection of tax and remission of delinquent tax can be applied in cases where the application for MAP is filed.

Suspension of seizure can be applied in cases where the request for domestic appeal is filed within the prescribed period of time and the required conditions, such as provision of collateral, are fulfilled.

Other dispute resolution mechanisms


Government Website




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