Customs valuation of transfer pricing adjustment, Japan | KPMG Global
Share with your friends

Japan: Retroactive transfer price adjustments, from customs valuation perspective

Customs valuation of transfer pricing adjustment, Japan

Japan’s customs bureau has issued guidance concerning how retroactive transfer price adjustments are to be addressed from a customs valuation perspective.


Related content

The guidance about the customs valuation treatment of retroactive transfer price adjustments was issued as a “customs valuation opinion” (June 2017) on the question and answer (Q&A) section of the customs authority’s website.

The guidance opinion was in response to a specific importer inquiry, with the customs authority determining that the specific adjustments are to be considered part of the value declared to Japan’s customs agency. The determination was based on provisions contained within the sales contract between the importer and related foreign supplier and an advanced pricing agreement (APA) between the importer and the bilateral tax authority (that stipulates, in part, that the sales prices for the products to be imported are subject to review and adjustment after payment is made).

The customs agency further stated that the adjustments would be considered part of the customs value, whether the adjustments were upward or downward.


For more information, contact a professional with KPMG’s Trade & Customs practice in Japan:

Masaharu Umetsuji | +81 3 6229 8070 | 

Kozu Takayuki | +81 3 6229 8205 |

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal