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This Practice Note contains a jurisdiction-specific Q&A guide to tax controversy in Japan published as part of the Lexology Getting the Deal Through series by Law Business Research (published: May 2021).
Authors: Anderson Mōri & Tomotsune—Eiichiro Nakatani; Yutaka Shimoo
Relevant tax acts
Articles 30 and 84 of the Japanese Constitution require that all taxes be imposed by acts of the Diet. The legislation that is relevant to the procedural aspects of taxes in Japan includes:
the National Tax General Rule Act (Act No. 66 of 1962), which deals mainly with matters generally related to national taxes, such as time limits for the tax authority to issue tax assessments, penalties for failure to file tax returns and rules on tax audits;
the National Tax Collection Act (Act No. 147 of 1959), which stipulates the procedures for collection of national taxes; and
the National Tax Violation Control Act (Act No. 67 of 1900), which sets out the criminal procedures related to evasion of national taxes.
Some pieces of legislation that mainly deal with substantive aspects of national taxes also provide procedural rules related to national taxes, such as the Income Tax Act (Act No. 33 of 1965), the Corporation Tax Act (Act No.
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