Based on the recommendations of OECDfs Base Erosion and
Profit Shifting (gBEPSh) Project, the Act on transfer pricing
documentation has developed in Japan@(Outline of the
Revision of the Transfer Pricing Documentation (NTA June
) , which can not be ignored even for small and medium-sized foreign-affiliated corporations in Japan. Even though the scale of business in Japan is small, if a group's consolidated
total revenue amount is 100 billion yen or more,
predetermined notification and reporting are necessary.