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 

Organization

MAP and MAP APAs :

Office of Mutual Agreement Procedure in the National Tax Agency

Scope of MAP & MAP APA

Domestic guidelines & administrative arrangements

- MAP (Commissioner’s Directive on MAP, June 25, 2001 (last updated on August 29, 2011)

- APA (Section 5 of Commissioner’s Directive on the Operation of Transfer Pricing, June 1, 2001) (last updated on October 27, 2011) 

Time for filing

MAP: some tax treaties have provisions on time limits

APA: the day before the commencement 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, 5-5, 11(3), 5-17, 5-25(3)

User fees

Tax collection / penalty / interest

Suspension of collection of tax and remission of delinquent tax are to be introduced in FY 2007 tax reform.

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