Former Japanese Tax Official Predicts Increase in Transfer Pricing Disputes in 2013

Yuriko Nagano

TOKYO — In the next year and going forward, transfer pricing disputes involving Japanese corporations will increase, a former Ministry of Finance division director of international tax affairs said Dec. 12.

Sakura Shiga, who also was a Tokyo customs director general and is now a Japanese international tax lawyer, said Japanese corporations that decide to dispute transfer pricing charges have two options, based on the statement of dissatisfaction fronting principle:

• file an objection and dispute the charge in court, or

• request a mutual agreement procedure with Japan and the other country involved.

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