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In March 2021, as a part of Japan’s 2021 Tax Reform, the Diet passed into law a new measure that allows the Japanese tax authorities to assign a tax administrator to a non-resident taxpayer that the authorities believe has a Japanese tax payment obligation. Under this new measure, the tax authorities will have the ability to designate certain domestic parties, either related or unrelated to the offshore taxpayer (eg unrelated operators of digital platforms “platformers”), as a tax administrator. This law will apply from 1 January 2022.