In a globalized economy, more organizations have the chance to do business beyond their own borders. But this brings with it an increased focus on tax compliance wherever transfer pricing is involved. The responsibility now rests on the taxpayer to ensure they meet the requirements of the National Tax Agency. And it is an area in which our transfer pricing consulting can assist.
The need to understand tax implications of transfer pricing – and any potential issues that may arise – can be an avoidable distraction. RSM Japan's role is to offer professional transfer pricing services that reduce your burden. Our in-depth knowledge of the Japanese tax structure brings valuable assistance – backed up by a global network with expertise in many other jurisdictions.
How we can support your business ambitions
Our transfer pricing specialists are equipped to support you in several ways. It ensures we can provide a comprehensive service that is shaped by your distinct needs.
It could include the preparation of a transfer pricing documentation, for example. If that is not sufficient to satisfy the tax authorities, we can go further. We establish robust transfer pricing solutions – adopting and implementing policies at all levels of an organization.
Explore our professional transfer pricing services
Tax compliance support
A corporate tax audit must include a review of Appendix 17 (4) of the tax return, in addition to the treatment of salaries for expatriates. The licensing of intangible property and the provision of services based on a transfer pricing perspective must also be factored into the process.
Failing to do so can sometimes result in not meeting your obligations. Tax compliance support from RSM Japan mitigates this risk. We work across all aspects of the audit process – and can develop internal policies for your organization too.
If you feel it will benefit your employees, we host in-depth seminars on tax matters as part of our transfer pricing consulting services. Please contact us for more information about this.
Transfer pricing risk assessment
Risk assessment and management is an area in which RSM Japan can offer extensive expertise. As such, our transfer pricing risk assessment services will consider the following measures:
- An assessment of your Group's risks during the early stages of international business.
- Selecting significant subsidiaries with the highest risk in a transfer pricing tax context.
- Evaluating the risk for the rest of the subsidiaries after the documentation is prepared.
- Reviewing how reasonable the prepared documents are i.e., providing a second opinion.
Transfer pricing documentation
Our transfer pricing solutions include two methods for the preparation of documentation:
- Full preparation: We will solely prepare the documentation.
- Hybrid: We collectively prepare the documentation with you.
There can also be cases where documents are prepared based on a foreign parent company's request. If so, our transfer pricing specialists will prepare the documents; taking into account that request – as well as the Group's transfer pricing policy and Japan's taxation risks.
Defensive support for transfer pricing tax audit
Japan tax authorities:
We can support your company, and mediate with the Japan tax authorities, during your next transfer pricing tax audits.
Foreign tax authority (Foreign subsidiary):
Our global network enables us to offer support in different countries during a transfer pricing tax audit with a foreign tax authority. We also offer our transfer pricing services to the Japan parent company if local tax authorities raise questions. At the same time, we take your entire Group's transfer pricing risks into account.
Mutual agreement procedure support
Advance Pricing Agreements (APAs) support:
APAs are an agreement between a multinational company and the tax authorities. They state the method and prices to be applied by the company. It starts with a preliminary consolidation before the APA application is prepared. But Advanced Pricing Agreement support is available to companies throughout the process – including the submission and due diligence.
Mutual Agreement Procedure (MAP) support:
Mutual Agreement Procedure support covers the preparation and submission of a MAP request when the assessment fails to meet the taxpayer's transfer pricing policy or OECD Guidelines.
Make us your trusted transfer pricing consulting partner
Our professional transfer pricing services are intended to have two main outcomes. The first is to make sure your organization is fully compliant without taking your focus off your objectives. The second is to educate you about the implications of doing business at home and abroad.
At RSM Japan, we combine the benefits of our knowledge and experience with the support of a global network. It puts us in a position where we can deliver essential transfer pricing solutions to maximize your business potential. Would you like to learn more? Please contact us today.