Japan import structure · ACP (税関事務管理人)

Import consumption tax when a non-resident is the importer

Appointing an Attorney for Customs Procedures (税関事務管理人) puts a Japan-based representative on your customs procedures. It is not what decides whether the consumption tax you pay at the border can be deducted. That follows who is named as the declarant on the import permit, and whether that party files a Japan consumption tax return at all. Two separate decisions, under two separate statutes, to two separate authorities.

Order the ACP appointment setup · USD 500 Check ACP eligibility

Online ordering is for companies with no registered entity, office or address in Japan, for imports and exports alike. Food, drink, additives, food-contact goods and children's toys imported into Japan may also need an Importer of Record arrangement, quoted separately. Checkout and the agreement are in English.

Outside Japan

  1. Your company

    Stays the importer and funds the duty and the import consumption tax at the border.

In Japan

  1. Japan Customs

    Levies duty and consumption tax on the withdrawal of the goods from the bonded area, and decides release.

  2. Import permit (輸入許可通知書)

    Names the declarant, and is the document the consumption tax input credit on an import is evidenced by.

  3. National Tax Agency (国税庁)

    Receives the consumption tax return. A different authority from Japan Customs, recognising a different appointment.

Aplash, appointed ACP (税関事務管理人)

Holds the appointment made under the Customs Act (関税法) for specified customs procedures, and is the contact Japan Customs reaches for the entry.

The customs side and the national tax side are separate. The appointment under the Customs Act covers customs procedures. A consumption tax return is filed on the national tax side by a taxable person, through a Tax Agent appointed under the Act on General Rules for National Taxes, and prepared by a certified tax accountant.

Direct answer

Does appointing an ACP recover the import consumption tax?

Not by itself. The appointment under the Customs Act (関税法) puts a Japan-based representative on specified customs procedures; it does not make you a taxable person for consumption tax purposes and it does not file a consumption tax return. Under the Consumption Tax Act (消費税法第30条), the input credit is available only to a taxable person (課税事業者), and on an import it is evidenced by the import permit (輸入許可通知書) rather than a qualified invoice, running in principle to the declarant named on it. A non-resident with no address or office in Japan that has to file appoints a Tax Agent (納税管理人) under the Act on General Rules for National Taxes (国税通則法第117条), which is a different appointment from the ACP.

Three appointments, three statutes, routinely treated as one

  • Attorney for Customs Procedures (税関事務管理人), under the Customs Act (関税法第95条): the Japan-based representative for specified customs procedures. This is the appointment Aplash holds.
  • Tax Agent (納税管理人), under the Act on General Rules for National Taxes (国税通則法第117条): the domestic representative a non-resident taxpayer appoints to handle national tax matters. Any person with an address or residence in Japan may be appointed and the appointment itself requires no tax accountant qualification, so Aplash can hold this one as well as the customs appointment. It is ordered as its own service.
  • Qualified Invoice Issuer (適格請求書発行事業者), under the Consumption Tax Act (消費税法第57条の2): registration that lets you issue qualified invoices. It governs whether the recipient of your onward domestic sale can take a credit, and it is a separate question from the import.
  • The return itself is prepared and filed by a certified tax accountant (税理士), engaged directly by the taxpayer. Aplash holds the customs appointment and keeps the ACP record for each entry.

What the credit actually follows

  • The consumption tax paid at the border is charged on the withdrawal of foreign goods from a bonded area, under the Consumption Tax Act (消費税法第4条).
  • The input credit under the Consumption Tax Act (消費税法第30条) is available only to a taxable person (課税事業者). A party that is not one has nothing to deduct it against.
  • On an import the credit is evidenced by the import permit (輸入許可通知書) rather than a qualified invoice, and in principle runs to the declarant named on it.
  • So the name on the import declaration is a tax decision as well as a customs one, which is why it is worth settling before the first entry rather than after it.

The published carve-out, and how narrow it is

  • Consumption Tax Act Basic Notice (消費税法基本通達11-1-6) applies where a limited declaration (限定申告) is required: goods allocated under the tariff quota system (関税定率法第9条の2), or goods receiving a duty reduction or exemption under the Act on Temporary Measures concerning Customs (関税暫定措置法).
  • In those cases, where the declarant is a nominal party and a substantive importer exists separately, the input credit provisions may be applied to the substantive importer, but only where all three published conditions are met: it transfers the goods to the declarant for consideration after the declaration, it bears the consumption tax and local consumption tax on the withdrawal, and it retains the originals of the import permit in the declarant's name and of the receipt for that tax in the same name.
  • Outside those cases the treatment does not apply, so an ordinary commercial arrangement cannot rely on it.
  • Naming a party on the declaration that does not hold the substance of the import is a separate matter under the Customs Act, and no appointment cures it. Aplash reviews the importer facts before the appointment file is prepared for that reason.

What to settle before the first entry

  • Who will be named as the declarant on the import permit, and whether that party is, or intends to become, a taxable person in Japan.
  • Whether a Tax Agent is already appointed and who holds it. It can sit with a different party from the ACP, and often should.
  • Whether you will make onward domestic sales in Japan, which is where Qualified Invoice Issuer registration starts to matter to your buyers.
  • Your recoverable position is a conclusion for the certified tax accountant who signs the return, on your own facts and your own tax status. What we settle here is the customs side it rests on.

What does an ACP cost?

ACP fees

Questions asked before the first shipment.

Choose a question

Is the ACP the same as a tax agent?

No. They are separate appointments, under separate statutes, to separate authorities.

The ACP is appointed under the Customs Act (関税法) for specified customs procedures; a Tax Agent (納税管理人) is appointed under the Act on General Rules for National Taxes (国税通則法第117条) to handle national tax matters for a non-resident taxpayer. One party can hold both roles, and holding one does not confer the other.

Can a non-resident company register as a Qualified Invoice Issuer?

Yes. A non-resident entity with no permanent establishment in Japan can register by appointing a Tax Agent.

Yes. A non-resident entity with no permanent establishment in Japan can register under the Consumption Tax Act (消費税法第57条の2) by appointing a Tax Agent (納税管理人) to file the application on its behalf, and registration makes the registrant a taxable person. What registration governs is whether the recipient of a domestic sale can take a credit, which is a separate question from the import.

Who can claim the consumption tax paid at the border?

Only a taxable person can take the input credit.

The input credit under the Consumption Tax Act (消費税法第30条) is available only to a taxable person (課税事業者), and on an import it is evidenced by the import permit (輸入許可通知書) rather than a qualified invoice, running in principle to the declarant named on it. Whether that describes your position turns on your own tax status and facts, which is a question for the certified tax accountant who prepares the return.

Who prepares the consumption tax return?

A certified tax accountant (税理士) prepares and files it, engaged directly by the taxpayer.

Aplash holds the customs appointment, keeps the ACP record for each entry, and coordinates so that the customs documents the return relies on are in order and available when it is prepared.

ACP is one of three possible import structures.

ACP support

The fees, the eligibility layers and the order action.

ACP support

Tell us who you expect to name as the declarant and whether a tax agent is already appointed, and we will confirm how the customs side should be set up before the first entry moves.