Recently, the National Tax Agency of Japan has released a guidance on mutual agreement procedures (MAP) on their website. This guidance has been prepared based on the recommendation 2.1 indicated in the final report on Action 14 (Making Dispute Resolution Mechanisms More Effective) of the Base Erosion and Profit Shifting (BEPS) project, as supplemental information to the Commissioner’s Directive on the Mutual Agreement Procedure (Administrative Guidelines).
The guide contains topics like as the purpose of the MAP, treaty provisions on MAP, Jurisdictions with which Japan can engage in MAP, time to complete MAP and the Japanese process for the request and fill out the MAP (including arbitration).
The National Tax Agency has also published the list of countries with which it has a treaty that contains a provision for MAP, as of 1 September 2017.
