Japan’s New Platform Taxation for Cross-Border E-Commerce　(FY2026 Japanese Tax Reform Outline)

1. Introduction of Platform Taxation for the Sale of Goods

The Japanese government has long regarded it as a major issue that consumption tax collected by foreign sellers (non-residents) through large e-commerce platforms such as Amazon is often not properly reported or paid.

According to the Government, it has been suggested that uncollected JCT related to fulfillment-based sales by foreign sellers in Japan may amount to approximately JPY 500 billion to JPY 1 trillion annually. (source: Government Tax Commission – Expert Panel, June 11, 2025)

To address this issue, Japan plans to shift the JCT payment obligation from individual foreign sellers to large-scale platform operators, requiring platforms to collect and remit JCT in aggregate.

Possible import JCT refund scenarios under the new platform taxation regime

Under the current system, when a foreign seller files JCT returns in Japan, import JCT paid at the time of importation can only be claimed as an input tax credit if the foreign seller itself acts as the Importer of Record (IOR).
This requires appointing an Attorney for Customs Procedures (ACP) and retaining the import permit issued by Japan Customs.

Under the new platform taxation framework, platform operators such as Amazon are expected to remit JCT on behalf of foreign sellers.
At the same time, import JCT paid by foreign sellers is expected to be creditable at the platform level, based on the tax reform outline.

While detailed regulations are yet to be finalized, the outline suggests the following structure:

• Foreign sellers will continue to pay import JCT to Japan Customs at the time of importation.
• Platform operators applying input tax credits will likely refund the corresponding import JCT amount to the foreign sellers.

However, input tax credits at the platform level will only be allowed for goods imported under the name of the foreign seller as the IOR.
Accordingly, platforms are expected to require import permits clearly showing the foreign seller as the importer.

As a result, if goods are imported under the name of a third party (e.g., a warehouse, or any IOR service provider), the platform may not be able to apply the input tax credit, and the foreign seller may not receive reimbursement of the import JCT.

Practical Implications for Foreign Sellers

For foreign sellers, it is therefore critically important to establish an import structure in which they act as the Importer of Record (IOR) by appointing an Attorney for Customs Procedures (ACP).

In preparation for the new system, we strongly recommend reviewing and restructuring import operations at an early stage to ensure compliance.

Notably, following the October 2023 revision of the Japan Customs Act, foreign sellers selling through e-commerce platforms such as Amazon have already been required to act as importers themselves through the use of an ACP.
From this perspective, the 2023 customs reform and the upcoming consumption tax reform are aligned in policy intent.

As specialists in ACP services, we have supported more than 200 foreign companies in establishing compliant import structures in Japan.
We are happy to assist you in building an import framework that enables proper treatment of import JCT and future tax adjustments with e-commerce platforms.

2. Review of the Small-Value Import Tax Exemption

Previously, when Japanese consumers ordered goods that were shipped directly from overseas sellers without using fulfillment services, imports with a taxable value of JPY 10,000 or less were exempt from consumption tax.

However, this exemption has been criticized for creating competitive distortions compared to domestic businesses that bear consumption tax on their procurement costs.

To address this issue, Japan plans to abolish the exemption for small-value goods, making sales of goods priced at JPY 10,000 or less (so-called “specified low-value assets”) subject to JCT, with the seller responsible for tax payment.

3. Outlook and Next Steps

At this stage, the reforms are based on the FY2026 Tax Reform Outline, and detailed legislation and operational rules will be finalized following Diet deliberations.

We will continue to monitor legislative developments closely and provide timely updates as further details become available.

If you have any questions regarding ACP services, Importer of Record structures, or the impact of the new platform taxation rules, please feel free to contact us.

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