(Uploaded on: 2023/9/27)

Rules for keeping documents for electronic transactions (after January 2024)

Summary

After January 2024, if invoices, receipts, contracts, etc. are provided in PDF or other electronic format, the electronic data must be stored in its electronic form. In addition, the electronic data must be stored according to the rules.

(Please note that not all rules can be explained here. Also, the rules may change in the future.)

 

Check whether the data is stored according to the rules

Question 1
(If yes, go to Question 2. If no, go to Question 7.)

Do you have measures in place to prevent tampering? *You need to do one of the following.

  1. Make rules on Administrative Procedures (recommended)
  2. Use timestamps
  3. Use a system that keeps a record of deleted files

 

Question 2
(If yes, go to Question 3. If no, go to Question 7.)

Do you have a display, printer, etc. so that you can show the data specified by the tax office?

 

Question 3
(If yes, go to Question 4. If no, go to Question 5.)

Is it possible to search for transactions by “date, amount, and counterparty”?

 

Question 4
(If yes, you are following the rules. If no, go to Question 6.)

Do all of the following requirements apply?
– Able to search for transactions by a specified range of dates or amounts.
– Able to search for transactions by combining two or more of the following items: date, amount, and counterparty.

 

Question 5
(If yes, go to Question 6. If no, go to Question 7.)

Do any of the following apply to you?
1. Sales for the base period (two years ago) were JPY 50 million yen or less
2. Able to present printed documents of electronic transactions, organized by date and counterparty

 

Question 6
(If yes, you are following the rules. If no, go to Question 7.)

Are you prepared to respond to requests from tax offices to present (downloaded) data of electronic transactions?

 

Question 7
(If you are eligible, go to Question 8. If no, you are not following the rules.)

Please check if you are eligible for the grace period.
Do you have a reason for not being able to do any of the items listed in questions 1 through 5?
For example, this is the case when the system is not ready in time and the environment for keeping electronic transaction data according to the rules is not in place.
However, if the system is in place and the electronic transaction data can be stored in accordance with the rules, but there are no circumstances such as lack of funds or manpower and the electronic transaction data is not stored in accordance with the rules, it is not considered that there is a reason and the grace period will not be applied.

 

Question 8
(If yes, go to Question 9. If no, you are not following the rules.)

Are you able to present printed documents of electronic transactions in the event of a tax audit, etc.?

 

Question 9
(If yes, you are eligible for the grace period. you are not following the rules.)

Are you prepared to respond to requests from tax offices to present (downloaded) data of electronic transactions?

 

 

Q&A

What is “Make rules on Administrative Procedures (recommended)” mentioned in question 1?
It is an internal document whose purpose is to prevent the correction and deletion of electronic transaction data. You can download the template (Japanese) from the link below. Pleasesee“電子取引に関するもの”.And“法人の例” isforacompany,and“個人事業者の例” is for a sole proprietor.

https://www.nta.go.jp/law/joho-zeikaishaku/sonota/jirei/0021006-031.htm

 

The rules apply only if I receive the data?

Not only when you receive, but also when you send.

 

Paper invoices, etc. have to be converted to data?

No.

 

How to meet the search requirements mentioned in question 3 and 4?
It is necessary to install a dedicated system, use spreadsheet (Excel), or use dates, amounts, and names of counterpart as file names.

 

More about the grace period?
Even if you are eligible for the grace period, the electronic data must be stored in its electronic form.
No prior application to the tax office is required.
The tax office has not indicated at this time when the grace period is scheduled to end.

 

Reference information

National tax agency summary (Japanese)

https://www.nta.go.jp/law/joho-zeikaishaku/sonota/jirei/tokusetsu/pdf/0023006-085_01.pdf

National tax agency Q&A (Japanese)

https://www.nta.go.jp/law/joho-zeikaishaku/sonota/jirei/pdf/00023006-044_03-5.pdf

National tax agency updates, overviews, etc. (Japanese)

https://www.nta.go.jp/law/joho-zeikaishaku/sonota/jirei/tokusetsu/01.htm