Although Japanese transfer pricing has over 20 years of legislative history and is one of the oldest transfer pricing taxation regimes, it remains for many foreigners one of the least understood transfer pricing systems in the world, in part because the rules are not as detailed as in other countries and due to the lack of sufficient case law. The authors aim to provide some insight into this with a review of the most significant aspects of Japanese transfer pricing, including a concluding section on the preparation strategies for transfer pricing documentation and tax audits.