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National Tax Agency of Japan releases information on Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs)
In November 2023, Japan’s National Tax Agency (NTA) released statistics on the MAPs and APAs for the Administrative Year ended 30 June 2023 (Administrative Year 2022)1 .
The statistics show a continued sharp increase in the number of APA applications. Two years ago, the number of applications was 146, the following year 188 and for the Administrative Year 2022 applications rose to 243. This does not include unilateral APA applications.
The number of MAP cases (other than those related to bilateral/multilateral APAs, i.e. cases regarding transfer pricing taxation and others) has not increased and has remained relatively steady, with 58 applications in the Administrative Year 2022, which is the same as last year.
Figure 1: Trends of MAP and APA applications and cases received2
1 Source: http://www.nta.go.jp/information/release/kokuzeicho/2023/sogo_kyogi/sogo_kyogi.pdf
2 Ibid
With respect to the geographic allocation of applications, the largest five counterparty countries in the Administrative year 2022 were as follows: United States (23%), followed by India (15%), China (14%), Korea (8%), and Germany (6%).
The number of cases unresolved at the end of the Administrative year 2022 was 742. By region, the largest portion was cases with Asia/Oceanian countries.
Figure 2: Administrative year-end 2022 inventory by region3
3 Ibid
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