Japan’s Cabinet Office Tax Commission has given its attention to four base erosion and profit sharing (BEPS) items, including the controversial Action 13 which relates to transfer pricing documentation. The other items under consideration by Japan are action 2 on hybrid mismatch arrangements, action 3 on controlled foreign companies legislation and action 8 concerning transfer pricing for transactions involving intangibles. The deadline to report to the Organization for Economic Cooperation and Development (OECD) on these items is only a few months away.
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