Key Takeaways from the 2022 Amendments to Japan’s Transfer Pricing Administrative Guidelines: Loans and Debt Guarantees (Part 1 of 2)
February 7, 2023
- Introduction
In June 2022, the National Tax Administration Agency (NTA) announced amendments to the Transfer Pricing Administration Guidelines. The amendments are thought to reflect the January 2022 update to the OECD Transfer Pricing Guidelines on financial transactions, and they revise Japan’s legislation on the treatment of financial transactions and cost contribution agreements (CCA). It should be noted that this may affect Japanese companies operating outside of Japan, including those operating in the United States.
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