The number of field audits in Japan has been increasing each year, and is now returning to the level seen prior to the COVID-19 pandemic (see our Tax Controversy Japan Update 2024). Foreign multinationals are therefore likely to face a tax audit in the near future (if not already), and while tax audits may result in disagreements between a company and the tax authorities, it could be in best interests of the company to try and resolve those differences during the course of the tax audit.