Japanese tax rules have many "gray" areas where tax rules are not certain.
In such gray areas, the national tax authority exercises its given power, and in this sense, taxpayers in Japan are very vulnerable.
The above situation doesn't allow taxpayers in Japan to take aggressive or even reasonable tax plannings because if such tax planning ideas are deemed as tax avoidance by the tax authority, then the taxpayers can hardly succeed in defending themselves.
The fact that there are few tax lawyers in Japan gets situations worse for taxpayers, as those taxpayers are not legally protected whereas the tax authority is getting stronger.
It is a tax accountant who usually supports a taxpayer in Japan, but a tax accountant is just an accountant and can't legally protect the taxpayer. What a tax accountant could do for its client is just to infer the tax authority's interpretation of uncertain tax rules somehow, which does not make a taxpayer's position stable.
So, I personally think that the Japanese tax authority "intentionally" creates unclear tax rules and exercises its power to make a judgement in the uncertain areas in favor of them.
If I'm right, what the Japanese tax authority is doing is very similar to what tax authorities in developing countries do. It's at least not a tax authority in a democratic nation. I hope the tax authority is improved urgently.
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