In Japan, only the Importer of Record (IOR) is eligible to deduct input (import) consumption tax in principle
The taxpayer liable for the Japan Consumption Tax on Imported Goods from the bonded area, and is considered the importer under Japanese customs law. Under customs law, the importer is defined as the taxpayer, known as the “Importer of Record – IOR” (Customs Law Articles 6 and 7(1), Basic Customs Notification 7-1).
Since the Importer of Record (IOR) is liable for the tax on taxable goods, such an entity, as a business, is eligible to deduct the related Japan Consumption Tax under the Consumption Tax Law (Consumption Tax Law Article 30, Paragraphs 1(3) and (4)).
As of October 1, 2023, amendments to the Customs Regulations have tightened the definition of who can be an “Importer of Record (IOR)”. Only those involved in the transaction, such as buyers who import through sales transactions or those with ownership and disposal rights over the goods, are allowed. Third parties uninvolved in the transaction cannot be Importers of Record (IOR). Foreign corporations without a physical presence in Japan (non-residents) can use our Attorney for Customs Procedures (ACP) service, allowing non-residents themselves to become Importer of Record (IOR) and deduct (or refund) import Consumption Tax.
We have extensive experience in facilitating such tax deductions (or refunds).
Case of Different Substantial Importer and Importer of Record
According to the Tokyo District Court decision on February 20, 2008, “In principle, a tax system where taxable entrepreneurs themselves deduct the taxes paid at the import stage should be assumed. Unless there are special circumstances, it should be understood that a plaintiff who is not the importer of record will not have their consumption tax deductible.” It indicates that tax declarations made in the name of a third party are not intended by law. We can learn from this court case that only the Importer of Record (IOR) has the right to deduct input tax amounts.
In very limited cases, substantial importers who are not the formal Importer of Record are allowed to deduct input tax amounts.
Practically, it is appropriate to assume that entities who are not the Importer of Record (IOR) are not allowed to deduct import consumption tax.
An exception that allows the deduction of input tax amounts for those not being the importer of record exists under Basic Consumption Tax Notification 11-1-6 “Handling in Cases Where the Substantial Importer and the Importer of Record Differ”. This directive states that even if the importer of record differs from the substantial importer, the following conditions, if met, allow the substantial importer to deduct the consumption tax paid on their taxable goods:
- The substantial importer sells the taxable goods to the importer of record (manufacturer, etc.) for a consideration after importing.
- The substantial importer bears the consumption tax amount related to the retrieval of the taxable goods.
- The substantial importer preserves the original import permit and receipt of the consumption tax related to the retrieval issued in the name of the importer.
*Please bear in mind that the applicability of this exceptional rule is extremely limited. Therefore, as a general rule, only the Importer of Record (IOR) is eligible to claim input Japan Consumption Tax (JCT).
Japanese Customs System Reform: Clarification of Importer Definitions
Starting October 1, 2023, Japanese Customs has instituted a pivotal reform aimed at addressing the issue of foreign sellers improperly designating third parties (such as forwarders or customs agents) as importers.
This revision necessitates foreign corporations to utilize an Attorney for Customs Procedures (ACP) to assume the role of Importer of Record (IOR) directly in many cases. The practice of merely nominally appointing another entity as the importer is no longer feasible.
Notably, foreign corporations that act as importers themselves, through the engagement of ACP, are eligible for Japan Consumption Tax (JCT) benefits.
As a dedicated ACP firm, we ensure compliance with the law to facilitate correct import procedures, allowing you to trust us with your importation requirements confidently. We are eager to engage in further discussions with you.
Revisions Effective October 1, 2023:
Definition of the Importer
- Regarding a cargo imported under import transaction, an importer is equivalent to “a person who imports a cargo” defined in Article 6-1 (1), General Notification of the Customs Act. ….. This means, the Consignee, etc., in the case of imports conducted through normal transactions between an overseas seller and a Japanese buyer
- In the cases other than above, an importer is a Person Having the Right of Disposal of the import cargo at the time of import declaration. If there is another person who acts on the purpose of the import*, that person is also included :
In case of a cargo imported:
– under lease contracts, a person who rents and uses the cargo.
– for consignment sales, a person who sells the cargo in the name of himself/herself (consignee) by accepting the commission.
– for processing or repairing, a person who processes or repairs the cargo.
– for disposal, a person who disposes the cargo.
Importer Defined as the “Person Having the Right of Disposal”
One of the most notable aspects of the amendment is the clarification that the “person having the right of disposal” is regarded as the importer under Japan Customs law. The term “right of disposal” is similar to ownership, but not identical. Although there is no explicit definition in the customs-related legislation, according to Japan Customs, it refers to the authority to decide how the goods will be handled after being released into Japan—for example, whether to sell the goods or to enter into a sales contract.
For additional information, please refer to the following resources:
- Japan Customs: Leaflet(English) Revision of Import Declaration Items and Attorney for Customs Procedure (ACP) System
Our Japan Consumption Tax (JCT) Representative Services
At ACP Japan, we provide a comprehensive one-stop service that covers both customs procedures through the Attorney for Customs Procedures (ACP) and Japan Consumption Tax (JCT) procedures with the National Tax Agency through a designated JCT Tax Representative.
By working closely with our trusted partner tax accountants, we act as your ACP while maintaining close coordination and information sharing with the tax representative.
This collaboration ensures the proper deduction and refund of Japan Consumption Tax paid at the time of importation.
Our ACP Service: The Best Solution for the Japan Importer of Record (IOR) and Exporter of Record (EOR)
ACP is an effective solution for addressing Importer of Record (IOR) and Exporter of Record (EOR) requirements in Japan. Through our ACP service, non-resident entities located outside Japan are able to import and export goods as Non-Resident IOR and EOR.
Below is an overview of our basic scope of work, together with a diagram illustrating the operational structure of the ACP service. Once ACP registration is completed, the non-resident entity can act as the Importer of Record (IOR) and Exporter of Record (EOR) in Japan.
Scope of Work – How We Can Assist
- Consultation with Japan Customs to support successful ACP registration.
- Liaison with relevant stakeholders, including freight forwarders and Japan Customs, to ensure the smooth and compliant import and export of goods.
- Assistance in preparing and reviewing import and export clearance documentation.
- Support in the calculation of customs value, in accordance with the Japan Customs Tariff Act.
- Assistance with advance rulings on HS classification, customs valuation, and rules of origin.
- Import compliance support for regulated products, including Domestic Administrator (sometimes referred to as “Domestic Representative”) Services under the Product Safety Acts (PSE/PSC) and food-related products regulated under the Food Sanitation Act.
- Support for security export control, including list-based classification, catch-all control assessment, and assistance with export license applications to the Ministry of Economy, Trade and Industry (METI).
- Record-keeping support in accordance with Article 95 of the Japan Customs Law.
- Provision of professional trade and customs advisory services to address and resolve issues that may arise during import or export operations.
**Both import and export activities can benefit from the use of an ACP (Attorney for Customs Procedures). This support is applicable in scenarios where a non-resident acts as the Importer of Record (IOR) for imports and as the Exporter of Record (EOR) for exports.
Three Steps to Initiate Shipments Under the ACP Program:
- Quotation Review to Contract Conclusion: Upon receiving your contact details, we will promptly provide a quotation for your review.
- Commencing the Registration of ACP (Attorney for Customs Procedures) to Japan Customs: This process is generally completed in about two weeks.
- Initiation of First Shipment, Import/Export

Track Record – Attorney for Customs Procedures (ACP) Services
We have supported import and export operations in Japan for over 200 clients across more than 40 countries.
Examples of International Logistics Partners We Have Worked With
We have a proven track record of working with a wide range of logistics providers. As the Attorney for Customs Procedures (ACP), we handle customs-related responsibilities while logistics companies manage transportation and warehousing operations.
- Apex International
- Brink’s
- CEVA Logistics
- Coshipper
- Crane Worldwide Logistics
- DB Schenker
- DGX (Dependable Global Express)
- DHL Express
- DHL Global Forwarding
- Dimerco
- DSV Air & Sea
- Expeditors
- FedEx Express
- FERCAM
- GOTO KAISOTEN Ltd.
- Harumigumi
- Herport
- ICL Logistics
- JAS Forwarding
- Kintetsu Express
- Kokusai Express
- Kuehne + Nagel
- Mitsubishi Logistics
- MOL Logistics
- Nankai Express
- Nippon Express
- OIA Global
- PGS
- Rhenus Group
- Röhlig
- Sankyu
- Sanyo Logistics
- Scan Global Logistics
- Seino Schenker
- SEKO Logistics
- Shin-Ei gumi
- Shiproad
- Sumitomo Warehouse
- UPS
- UPS Supply Chain Solutions
- Yamato Transport
…and many other logistics providers in Japan and around the world.












