Tax controversy—Japan—Q&A guide

The following Tax practice note provides comprehensive and up to date legal information covering:

  • Tax controversy—Japan—Q&A guide
  • 1. What is the relevant legislation relating to tax administration and controversies? Other than legislation, are there other binding rules for taxpayers and the tax authority?
  • 2. What is the relevant tax authority and how is it organised?
  • 3. How does the tax authority verify compliance with the tax laws and ensure timely payment of taxes? What is the typical procedure for the tax authority to review a tax return and how long does the review last?
  • 4. Are different types of taxpayers subject to different reporting requirements? Can they be subjected to different types of review?
  • 5. What types of information may the tax authority request from taxpayers? Can the tax authority interview the taxpayer or the taxpayer’s employees? If so, are there any restrictions?
  • 6. What actions may the agencies take if the taxpayer does not provide the required information?
  • 7. How may taxpayers protect commercial information, including business secrets or professional advice, from disclosure? Is the tax authority subject to any restrictions concerning what it can do with the information disclosed?
  • 8. What limitation period applies to the review of tax returns?
  • 9. Describe any alternative dispute resolution (ADR) or settlement options available.
  • More...

Tax controversy—Japan—Q&A guide

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

1. What is the relevant legislation relating to tax administration and controversies? Other than legislation, are there other binding rules for taxpayers and the tax authority?

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:

  1. 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;

  2. the National Tax Collection Act (Act No. 147 of 1959), which stipulates the procedures for collection of national taxes; and

  3. 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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