AKIA TAX CONSULTANTS K.K
Address：2F Shouei-Kannai Bldg.,2-22, Sumiyoshi-cho,Naka-ward, Yokohama City,
Kanagawa Prefecture,231-0013 Japan
Phone：＋81-45-308-6561
Fax：＋81-45-308-6562
Master File
Outline
・Reporting entity to submit it ： Japanese
corporations or foreign corporations with PE that is a Constituent Entity of a Specified MNE Group
・Items to be reported：Organizational structure of the Specified MNE Group as well as the outline of its business operation and financial condition, and other items as listed in the items of Article
22.10.5 Paragraph 1 of the Ordinance
corporations or foreign corporations with PE that is a Constituent Entity of a Specified MNE Group
・Items to be reported：Organizational structure of the Specified MNE Group as well as the outline of its business operation and financial condition, and other items as listed in the items of Article
22.10.5 Paragraph 1 of the Ordinance
・Start of application：Ultimate Parent Entity's fiscal year that begins on April 1, 2016 or thereafter
・Deadline for submission：Within one year of the day following the one when the Ultimate Parent
Entity's fiscal year ends
Generally, Ultimate Parent Entity prepares Master File, however, Master File may not be prepared
depending on the group, such as not being requested to prepare Master File in the country of
residence of the Ultimate Parent Entity or the country of residence of other corporations within the
group other than Japan.
・Deadline for submission：Within one year of the day following the one when the Ultimate Parent
Entity's fiscal year ends
Generally, Ultimate Parent Entity prepares Master File, however, Master File may not be prepared
depending on the group, such as not being requested to prepare Master File in the country of
residence of the Ultimate Parent Entity or the country of residence of other corporations within the
group other than Japan.
Generally, Ultimate Parent Entity prepares Master File, however, Master File may not be prepared
depending on the group, such as not being requested to prepare Master File in the country of
residence of the Ultimate Parent Entity or the country of residence of other corporations within the
group other than Japan.
depending on the group, such as not being requested to prepare Master File in the country of
residence of the Ultimate Parent Entity or the country of residence of other corporations within the
group other than Japan.
AKIA Services
Depending on your situation, we have two services as follows.
In addition, Master File can be prepared either in Japanese or English, however, please note that in
the case of English, you may be required to submit translated texts in Japanese as necessary.
(AKIA can provide translation service as well.)
In addition, Master File can be prepared either in Japanese or English, however, please note that in
the case of English, you may be required to submit translated texts in Japanese as necessary.
(AKIA can provide translation service as well.)
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1
|
If your group has already prepared or is preparing
Master File (English version). Review and submission of Master File (English version) Items to be reported in Master File in Japan conform to the final report
of the BEPS project. AKIA will submit the Master File to the tax office after reviews such as whether those items are covered and whether there is a description that may raise tax risks in Japan. |
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2
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If your group has not prepared Master File
AKIA will provide support for preparation. While consulting, it is also
possible to contact directly with the Ultimate Parent Entity etc. Please select from the following two options. |
| A | Preparation mainly by your group
AKIA will provide a list explaining the items to be reported in Master File in an easy-to-understand so that you can prepare Master File. AKIA will review the Master File and submit it to the tax office. |
| B | Preparation mainly by AKIA
AKIA will provide a questionnaire and request list. AKIA will prepare Master File based on the information from the list and submit it to the tax office. |