Updates on Japan Tax Reform Outline (FY2026) - Documents to be Retained for Intra-group Transactions -
JAPAN TAX BULLETINThe FY2026 Tax Reform Outline (published Dec 12, 2025) introduces tighter documentation rules for intra-group transactions, affecting companies of all sizes. This measure specifically targets arbitrary pricing or lack of documentation for intra-group services (including IP transfers and loans), such as shared cost facilities.