Japan - The OECD/G20 Base Erosion and Profit Shifting Initiative and the 2019 Tax Reform in Japan: Revisions to the Earnings Stripping Rules and the Introduction of Hard-to-Value Intangibles into Transfer Pricing
- J. Hagelin; S. Muto
- Bulletin for International Taxation, 2019 (Volume 73), No 5
- 16 April 2019
This article analyses the international aspects of the Japanese tax reform of 2019 relating to Actions 4 and 8-10 of the OECD/G20 Base Erosion and Profit Shifting initiative, which includes revisions to the earnings stripping rules and the implementation of an approach to hard-to-value intangibles into domestic transfer pricing legislation.