Japan closed 174 mutual agreement procedure (MAP) cases during the fiscal year ending June 30, 2014, a record high, Japan’s National Tax Agency (NTA) said in an English-language report released September 28.
Of the closed MAP cases, 141 were bilateral advance pricing agreements (APA) cases, the agency said in the paper, the National Tax Agency Report 2015.
The NTA also received a large number of new MAP requests during the period. The agency received 197 new requests, of which 152 involved bilateral APAs.
The NTA said that MAP cases are becoming more difficult because there has been an increase in cases with emerging countries that have less experience in MAP.
As of June 30, 2014, Japan’s inventory of bilateral APAs involved 20 countries: 10 European nations, 8 countries or economies in Asia/Pacific, and the US and Canada.
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