On September 29, 2015, TEI submitted comments to the Japanese Ministry of Finance regarding proposed changes to Japan's taxation of cross-border supplies of services, as most recently articulated in Japan's May 2015 Revision of Consumption Taxation on Cross-Border Supplies of Services Guidelines. TEI recommended using a true object test to define "electronic services" and proposed changes to the classification of business-to-business and business-to-consumer electronic services, the reverse charge mechanism notification requirement, the business-to-consumer exemption threshold, eligibility criteria for the purchase tax credit, and the taxation of electronic services sold through app stores and portals.
TEI's comments were prepared under the aegis of TEI's European Indirect Tax Committee, whose chair is Paula Regales. Pilar Mata, Tax Counsel for TEI, coordinated the preparation of TEI's comments.