Global Tax Alert (News from Transfer Pricing) | 21 February 2017

Japan introduces Country-by-Country Reporting notification requirements

  • Share

Executive summary

Japan has introduced notification requirements related to Country-by-Country Reporting (CbCR) under Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting Action 13. This Tax Alert sets out the details of the requirements.

Detailed discussion

Multinational groups impacted

The notification requirements are for groups with an entity in Japan (Japanese and overseas headquartered companies) that is part of a group that will be required to create a CbCR per the Japanese requirements.1


Japan has followed the suggested deadline within Article 3,2 of the last day of the reporting fiscal year (RFY) of the multinational group.


The notification requirement relates to RFYs commencing from or after 1 April 2016. Companies with years ending 31 March 2017 will be first impacted by the requirement. For companies with a RFY ending in December, the first deadline will be 31 December 2017.

Contents of notification

The notification requires basic information including details of the ultimate parent entity, surrogate parent entity, and entities in Japan. The form also covers the instances when there are multiple entities in Japan and one entity will submit on behalf of the others.

Method of submission

The notification should be submitted electronically via E-tax (the same system as other items such as the master file and tax return).


1. For further information, see EY Global Tax Alert, Japan releases guidance on transfer pricing documentation requirements, dated 7 June 2016.

2. Model Legislation Related to Country-by-Country Reporting, Action 13: Country-by-Country, Reporting Implementation Package, OECD 2015.

For additional information with respect to this Alert, please contact the following:

Ernst & Young Tax Co., Tokyo
  • Ichiro Suto
    +81 3 3506 2637
  • Karl Gruendel
    +81 3 3506 2389
  • Tatsuhide Kanenari
    +81 3 3506 1364
  • Keith Thomas
    +81 3 3506 3896

EYG no. 00804-171Gbl