At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-09-30. Tax authority: National Tax Agency (NTA). Summaries are simplified; check the linked official source before relying on them.
The law
#Transfer pricing rules are in Article 66-4 of the Act on Special Measures Concerning Taxation (ASMT), with CbC and master file rules in Articles 66-4-4 and 66-4-5. NTA guidance is in the Commissioner's Directive on the Operation of Transfer Pricing. Japan follows the OECD Guidelines.
Documentation
#Groups with consolidated revenue of at least JPY 100bn in the prior year must file an ultimate parent notification, a CbC report and a master file through e-Tax. A local file must be prepared by the CIT return deadline (contemporaneous documentation) for dealings with a foreign related party that totalled JPY 5bn or more, or JPY 300m or more for intangibles, in the prior year. This is tested per foreign related party. On request in an audit, the local file must be presented by a date set by the examiner within 45 days; documents for smaller dealings within 60 days. Local files are kept in Japan for 7 years. Master file may be in Japanese or English; CbC report in English; local file language not fixed, but a Japanese translation can be requested.
Methods
#Accepted methods are CUP, resale price, cost plus, profit split, TNMM and, since 2019, the discounted cash flow method. The most appropriate method applies. If a result falls outside the interquartile range, the NTA generally adjusts to the median.
Penalties
#If the local file is not provided by the set date, the NTA can estimate the arm's length price (presumptive taxation) and question comparable companies. Failing to file the CbC report or master file on time without good reason can be fined up to JPY 300,000. Normal underpayment penalties apply to TP adjustments.
Pillar Two
#Japan applies the IIR to fiscal years starting on or after 1 April 2024, and the UTPR and a QDMTT from 1 April 2026. Japanese entities file a GIR (or a notification if the parent files centrally) 15 months after year end, 18 months for the first year. IIR and QDMTT returns, with payment, follow the same timetable when tax is due.
Other rules
#Unilateral and bilateral APAs are available under the Commissioner's Directive. Japan also has earnings stripping rules (net interest above 20% of adjusted income is not deductible) and thin capitalisation rules (3:1 debt to equity with foreign controlling shareholders).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Notification for Ultimate Parent Entity (via e-Tax) Filed through e-Tax by the last day of the ultimate parent's fiscal year. One entity can file for the others. | Last day of the fiscal year (e.g. Jan 5, 2026) (moved from Dec 31, 2025, a public holiday) | Japanese constituent entities of groups with consolidated revenue of JPY 100bn or more in the prior fiscal year. | NTA: Outline of the Revision of the Transfer Pricing Documentation |
| 2 | Corporation tax final return Due within 2 months after the fiscal year end. Most large companies get a one-month extension (to 3 months) because their articles of incorporation hold the shareholders' meeting later (Corporation Tax Act Art. 75-2). Companies with an accounting auditor can ask for a longer extension. Tax payment is still due at 2 months, with interest during the extension. | Extended: on application, 1 more month (Corporation Tax Act art. 75-2) (e.g. Mar 31, 2026); original due date Feb 28, 2026 | All Japanese corporations. | NTA: Extension of filing deadline under the articles of incorporation (C1-17) |
| 3 | Schedule 17(4): statement on foreign related parties (Beppyo 17(4)) Attached to the corporation tax return. Lists each foreign related party, the transactions with it, and the TP method used. | With Corporation tax final return (extended) (e.g. Mar 31, 2026); original due date Feb 28, 2026 | Any corporation with transactions with foreign related parties. | NTA: How to complete Schedule 17(4) |
| 4 | Local file (contemporaneous documentation) Must be prepared or obtained by the CIT return deadline and kept in Japan for 7 years. It is not filed. In an audit it must be presented by a date the examiner sets, within 45 days of the request. | With Corporation tax final return (extended) (e.g. Mar 31, 2026); original due date Feb 28, 2026 | Corporations whose transactions with one foreign related party totalled JPY 5bn or more in the prior year, or JPY 300m or more for intangibles. | NTA: Outline of the Revision of the Transfer Pricing Documentation |
| 5 | Master file (via e-Tax) Filed through e-Tax within one year after the end of the ultimate parent's fiscal year. Japanese or English. One entity can file for the others. | 12 months after year end (e.g. Jan 4, 2027) (moved from Dec 31, 2026, a public holiday) | Japanese constituent entities of groups with consolidated revenue of JPY 100bn or more in the prior fiscal year. | NTA: Outline of the Revision of the Transfer Pricing Documentation |
| 6 | Country-by-country report (via e-Tax) Filed in English through e-Tax within one year after the end of the ultimate parent's fiscal year. | 12 months after year end (e.g. Jan 4, 2027) (moved from Dec 31, 2026, a public holiday) | Japanese ultimate parent of a group with consolidated revenue of JPY 100bn or more in the prior fiscal year, or a Japanese entity that must file locally. | NTA: Outline of the Revision of the Transfer Pricing Documentation |
| 7 | GloBE information return (Tokutei Takokuseki Kigyo Group Hokoku Jiko) or notification Filed by e-Tax 15 months after year end, 18 months for the first year (30 September 2026 for a March 2025 year end, 30 June 2027 for a December 2025 year end). If the parent files centrally abroad under an exchange agreement, a notification is filed in Japan instead. Not filing without good reason can mean up to 1 year in prison or a fine up to JPY 500,000. The site uses 15 months for 2025 year ends because the 18-month first-year period only applies in the group's first year in scope of Pillar Two anywhere; a group first in scope here gets 18 months. | 18 months after year end (first year) (e.g. Jun 30, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | EY Japan: Global Minimum Tax filing requirements for foreign-owned Japanese entities |
| 8 | International minimum tax return (IIR) and payment Needed only when Japanese IIR top-up tax arises. Due with payment 15 months after year end, 18 months for the first year. Applies to fiscal years starting on or after 1 April 2024; the UTPR from 1 April 2026 follows the same timetable. The site uses 15 months for 2025 year ends because the 18-month first-year period only applies in the group's first year in scope of Pillar Two anywhere; a group first in scope here gets 18 months. | 18 months after year end (first year) (e.g. Jun 30, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | NTA: C8-1 International minimum tax return |
| 9 | TP documents on request (local file 45 days; other documents 60 days) Local file: by a date set by the examiner within 45 days. Supporting documents, and documents for transactions below the contemporaneous thresholds: within 60 days. Missing the date allows presumptive taxation. | Within 45 days of a tax authority request | Any corporation with foreign related party transactions. | NTA: Outline of the Revision of the Transfer Pricing Documentation |
| 10 | Domestic minimum tax return (QDMTT) and payment New for fiscal years starting on or after 1 April 2026 (first due June 2028 for a March 2027 year end). Due with payment 15 months after year end, or 18 months if it is the group's first in-scope year. | Starts with years ending on or after 2027-03-31 | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | EY Japan: Global Minimum Tax filing requirements for foreign-owned Japanese entities |
Official texts
#- NTA website content, incl. Commissioner's Directive on the Operation of Transfer Pricing (English, unofficial translation) (Public Data License (PDL 1.0), compatible with CC BY 4.0; cite 'Source: National Tax Agency website (URL)' and flag edits)
- Act on Special Measures Concerning Taxation, Corporation Tax Act (Laws are not subject to copyright in Japan (Copyright Act, Article 13))