Interpretation of Tax Law and Treaties and Transfer Pricing in Japan and Germany

This work is the result of a conference held in September 1996 in Germany in honour of Professor Hiroshi Kaneko, Emeritus Professor of Tokyo State University. Some 60 scholars and practitioners of international tax law from Japan and Germany convened to discuss questions of common interest. The first part of the book explores the methods of interpretation of tax statutes and treaties used in both countries, particularly in light of the totally different structure of the Japanese language as compared to European languages. Such differences may be of potentially significant importance to the interpretation of tax treaties, usually concluded in two authentic language versions which are equally binding. The papers in the second part present a detailed analysis of issues of international transfer pricing in Germany and in Japan, highlighting important differences as well as surprising similarities of the two legal systems. The collection of expert papers provides an important contribution to the literature in the field of international and comparative taxation. For the tax practitioner it should be useful reading when he or she is confronted with Japanese tax treaties, the interpretation of which is contested, or with transfer pricing problems in connection with Japan.