Companies importing goods into Japan pay consumption tax at the border. For many, that tax never comes back. Whether it does, and how, depends entirely on the import structure chosen and whether the right registrations were in place before the first shipment cleared customs. This guide sets out how import consumption tax (輸入消費税) works, how the Qualified Invoice System (インボイス制度) governs credit eligibility, and what the recovery path looks like under each of the two primary non-resident import structures: IOR (Importer of Record, buy-and-sell) and ACP (Attorney for Customs Procedures / 税関事務管理人).
How Import Consumption Tax Works
Japan's Consumption Tax Act (消費税法) imposes a standard Japan Consumption Tax (消費税, JCT) rate of 10% on imported goods. The tax is assessed on the customs value of the shipment and paid at the point of customs clearance, before the goods are released. There is no payment deferral for non-residents.
For a shipment with a customs value of JPY 10 million, the import JCT liability at clearance is JPY 1 million. That amount is due regardless of whether the importer is a Japan resident or a foreign company, regardless of whether the goods are for resale or internal use, and regardless of the final destination of the goods within Japan.
The question that determines the full landed cost of importing into Japan is not whether the tax is paid. It always is. The question is whether it can be recovered.
The Qualified Invoice System and Input Tax Credits
The Qualified Invoice System (インボイス制度, QIS) took effect in October 2023. Under QIS, a business registered as a Qualified Invoice Issuer (適格請求書発行事業者) can issue qualified invoices (適格請求書) that allow downstream purchasers to claim input tax credits against their own JCT output liabilities. Unregistered businesses cannot issue invoices that carry input credit eligibility.
For importers, QIS has a direct consequence at the import stage. The import JCT paid at customs clearance is creditable against an importer's output JCT on its Japan domestic sales, but only if:
(a) the importer holds a valid QIS registration as a Qualified Invoice Issuer, and
(b) the importer files JCT returns with the National Tax Agency (国税庁, NTA) through a properly appointed Tax Representative (納税管理人) as required under applicable national tax rules.
Without both conditions, the JPY 1 million paid at clearance on a JPY 10 million shipment is a direct, permanent cost. It does not flow back.
The IOR Path: Aplash as the Importer
Under the IOR structure, Aplash is the legal importer named on the import declaration (輸入申告). Aplash buys the goods from the overseas seller, clears customs in its own name, and re-sells to the Japan buyer. This is a genuine buy-and-sell transaction, not an agency arrangement.
The import JCT question is fully resolved within Aplash's own tax position. Aplash pays the import JCT at clearance as the importer of record. Aplash then recovers that JCT as an input tax credit against its own JCT output liabilities arising from the re-sale of the goods in Japan. Aplash is a registered Qualified Invoice Issuer and issues a qualified invoice (適格請求書) to the Japan buyer, enabling the buyer to claim its own downstream input credit.
From the overseas client's perspective, the JCT exposure is absorbed into the commercial structure. The client does not appear on the import declaration, does not pay JCT directly, and does not need to maintain a Japan tax registration. The re-sale invoice from Aplash to the Japan buyer incorporates customs duties and import JCT as pass-through items at cost. The client's commercial engagement with Aplash is governed by the separate IOR service agreement.
This is the structurally simpler path for companies whose primary goal is getting goods into Japan without establishing a Japan tax presence.
The ACP Path: The Non-Resident as the Importer
Under the ACP structure, the non-resident company is the legal importer. The non-resident appears on the import declaration and bears the import JCT liability directly. Aplash, as a Japan resident, acts as the statutory procedural agent: the 税関事務管理人 (Attorney for Customs Procedures) appointed under the Customs Act (関税法).
The ACP appointment covers customs procedures. It does not, by itself, create the tax registration needed to recover the import JCT paid.
To recover import JCT under the ACP path, three elements must be in place:
(a) ACP appointment: Aplash appointed as 税関事務管理人 under the Customs Act (関税法) before any import declaration is filed.
(b) Tax Representative appointment: the non-resident appoints a Tax Representative (納税管理人) as its Japan domestic representative for all national tax matters including JCT. Aplash can serve directly in this capacity and file the required notification (納税管理人届出書) with the NTA.
(c) QIS Registration: the non-resident registers as a Qualified Invoice Issuer (適格請求書発行事業者) with the NTA before the first shipment for which a credit is sought. The application (適格請求書発行事業者の登録申請書) is filed by Aplash as the appointed Tax Representative.
Once all three are in place, the import JCT paid at clearance is creditable against the non-resident's output JCT on its Japan domestic B2B sales. The JCT return itself is filed by a licensed Tax Accountant (税理士) who handles the statutory return-filing obligations reserved to that profession.
Without all three elements, the import JCT is irrecoverable. The ACP appointment alone is not sufficient. The Tax Representative appointment alone is not sufficient. QIS registration alone is not sufficient. All three must precede the shipment for which the credit is claimed.
The Most Common Mistake: Importing Before QIS Registration Is Complete
Companies that establish ACP and begin importing before their QIS registration is processed by the NTA lose the input tax credit on every shipment that cleared customs before the registration effective date. This is not correctable retroactively. The Consumption Tax Act (消費税法) does not provide a mechanism to claim input credits on import JCT paid during a period when the importer was not a registered Qualified Invoice Issuer.
On a JPY 10 million shipment at the 10% rate, that is a JPY 1 million permanent cost per shipment. On recurring imports, the exposure compounds across every shipment in the unregistered window.
The sequencing is therefore critical:
(a) Confirm the import structure before the first shipment, not after.
(b) If the ACP path is chosen, complete all three registrations before the import declaration is filed for the first shipment where JCT recovery is expected.
(c) Allow lead time for NTA processing of the QIS registration application. NTA processing timelines vary; do not assume same-week registration.
When JCT Recovery Matters Most
The financial materiality of JCT recovery depends on three factors: shipment value, import frequency, and the buyer's own JCT position.
High-value goods: At a 10% rate, the absolute JPY amount at stake scales directly with customs value. A single JPY 50 million shipment carries JPY 5 million in import JCT. Whether that is recoverable or a permanent cost is a structuring decision, not a force of nature.
Recurring imports: Companies importing monthly or quarterly accumulate import JCT exposure rapidly. An unrecovered JPY 500,000 per shipment becomes JPY 6 million per year. The setup cost of correct registration is recouped quickly.
B2B sales into Japan: If the non-resident's Japan customers are themselves taxable businesses, those customers need to receive qualified invoices to claim their own input credits. A non-resident importer that is not a registered Qualified Invoice Issuer cannot issue valid qualified invoices, which disadvantages its Japan buyers and creates a structural price disadvantage versus competitors who are properly registered.
B2C or tax-exempt sales: If the end customers in Japan are individual consumers or the sales are otherwise outside the JCT credit chain, QIS registration is less urgent on the output side, but the import JCT recovery question on the input side remains. A company selling to consumers still paid import JCT and should evaluate whether it can be credited against other taxable output.
Practical Example
A non-resident technology company imports test equipment into Japan under an ACP structure. The customs value is JPY 10 million. Import JCT at 10% is JPY 1 million, paid at clearance.
Scenario A: ACP in place, QIS registration complete before shipment. The JPY 1 million is creditable against the company's output JCT on its Japan B2B equipment sales. Net JCT cost on this shipment: zero (offset by input credit). The company's Japan customers receive qualified invoices and claim their own downstream input credits.
Scenario B: ACP in place, QIS registration not yet complete at time of shipment. The JPY 1 million is paid at clearance and is not creditable. It is a direct cost of goods. It cannot be reclaimed after registration is obtained.
The difference in outcome between Scenario A and Scenario B is entirely a function of timing and registration sequencing, not the underlying commercial transaction.
The Tax Representative Requirement
Non-resident businesses engaging with the NTA, whether for JCT registration, JCT return filing, or any other national tax matter, must appoint a Tax Representative (納税管理人) as their Japan domestic point of contact. The 税関事務管理人 (ACP) appointment under the Customs Act (関税法) is a separate appointment covering customs procedures only. The two roles are legally distinct and must be appointed separately.
Aplash can serve directly as the Tax Representative (納税管理人) for non-resident clients, filing the required notification and the QIS registration application. The downstream JCT return filing, which is reserved to licensed Tax Accountants (税理士) under the Licensed Tax Accountant Act (税理士法), is handled by a partner 税理士 and billed as a separate pass-through.
Choosing the Right Structure
The IOR and ACP structures are not alternatives to the same outcome. They are distinct legal frameworks with different parties named on the import declaration, different liability profiles, and different JCT recovery paths.
IOR: Aplash is the importer. Aplash absorbs and recovers the import JCT within its own tax position. The client has no Japan tax registration requirement arising from the import itself.
ACP: The non-resident is the importer. The non-resident pays import JCT directly and recovers it through its own Japan JCT registration. This path requires establishing and maintaining a Japan tax presence before importing.
The choice between the two structures depends on the client's commercial intent in Japan, the volume and duration of imports, the nature of downstream Japan sales, and the client's appetite for maintaining ongoing Japan tax registrations. Each case should be assessed individually before the first shipment.
This article is informational only and does not constitute legal, tax, or regulatory advice. Consult a qualified advisor before acting on the content. Last updated: 2026-06.