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National Tax Agency of Japan releases information on Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs)
In November 2025, Japan’s National Tax Agency (NTA) released statistics on the Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) for the NTA Administrative Year ended 30 June 2025 (Administrative Year 2024).1
For the Administrative Year 2024, APA applications increased to 194, reversing the reduction for the prior year when applications dropped to 167. This rebound brings the volume closer to the peak of 243 in Administrative Year 2022. This does not include unilateral APA applications, of which there are many.
The number of MAP cases (regarding transfer pricing and others) amounted to 86 applications in the Administrative Year 2025.
Figure 1: Trends of MAP and APA applications and cases received
1 Source: https://www.nta.go.jp/information/release/kokuzeicho/2025/sogo_kyogi/sogo_kyogi.pdf
With respect to the geographic allocation of applications, the largest five counterparty countries in the Administrative Year 2024 were as follows: United States (25%), followed by India (15%), China (13%), Korea (12%), and Germany (5%).
The number of cases unresolved at the end of the Administrative Year 2024 was 773 (MAP and APA cases). By region, the largest portion was cases with Asia/Oceanian countries with 295 open APA cases alone.
Figure 2: Administrative Year 2024 inventory by region
Contact
Ernst & Young Tax Co.
Karl Gruendel, Partner
Keith H Thomas, Associate Partner
Allen Wang, Director
Tiffany Huang, Manager
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