Statute of limitations for correction/assessment by the tax authorities and taxpayers

An outline of the statute of limitations for correction / assessment by the tax authorities and for a request for correction by taxpayers is as shown below. (Source: Ministry of Finance website)

 

Statute of limitations for correction / assessment by the tax authorities

General
	General correction or assessment	5 years from the filing deadline (6 years for corporate tax under transfer pricing rules and for inheritance tax)
	Correction or assessment -  due to falsification or fraud -  under Japanese exit tax rules	7 years from the filing deadline
	Correction of current net operating loss for corporate tax purposes	10 years from the filing deadline
Special
	Correction or assessment based on court ruling or decision	6 months from the date of ruling
	Correction due to loss of economic outcomes	3 years from the occurrence of the reason for the loss
	Correction related to a request for correction in the case of a deadline extension due to a disaster	6 months from the date of request for correction

Statute of limitations for request for correction by taxpayers

General
	General request for correction	5 years from the filing deadline (6 years for corporate tax under transfer pricing rules and for inheritance tax)
	Request for correction of current net operating loss for corporate tax purposes	10 years from the filing deadline
Special
	Request for correction based on a subsequent event, e.g., the case where a court determines that any fact based on which the tax basis is calculated is untrue	2 months from the occurrence of the event

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