Issuing Qualified Invoices in Japan: A Field Checklist

A qualified invoice (適格請求書, tekikaku seikyusho) is the sales invoice a registered business in Japan gives a business customer so that the customer can credit the consumption tax (消費税, shohizei) it pays. It must show six items set out in Article 57-4(1) of the Consumption Tax Act, and the same Article governs return and discount invoices, corrections and invoices sent as data. This checklist takes a Japan subsidiary's sales invoice field by field, so an HQ billing team can test its template before the first invoice goes to a Japanese customer.

How the invoice fits into the subsidiary's wider tax position is set out in our pillar on where Japan consumption tax departs from group VAT policy.

Key Takeaways

• Six fields decide whether it counts. An invoice missing the T-number, the rate, or the tax per rate is not a qualified invoice.
• One rounding per rate per invoice. A billing engine that rounds tax on each line and adds the results produces a figure the law does not accept.
• The tax amount must be in yen. Prices, descriptions and labels may be in English and in dollars or euros, but the consumption tax by rate may not.
• Credit notes are invoices too. Discounts, rebates and returns of JPY 10,000 or more need a qualified return invoice with its own fields (Article 57-4(3)).
• Electronic copies carry their own rules. An invoice sent as a PDF or EDI file is kept as data with one integrity measure and, unless a waiver applies, search by date, amount and customer; a printout meets the consumption tax rule only, not corporate tax.

Who Must Issue a Qualified Invoice, and When

A registered issuer must give a qualified invoice when a taxable business customer asks for one; a business that is not registered cannot issue one.

The duty arises on a taxable sale in Japan when a taxable business customer requests the invoice (Consumption Tax Act Article 57-4(1), NTA invoice system Q&A, question 31). Only a business registered with the tax office can issue one; see qualified invoice issuer registration for a new subsidiary; how the invoice system works for foreign companies covers the buyer side.

A shorter simplified qualified invoice (適格簡易請求書, tekikaku kan'i seikyusho) is allowed only for retail, restaurants, photography, travel, taxis, public parking and similar businesses selling to an unspecified number of customers (Article 57-4(2), Enforcement Order Article 70-11, Q&A question 24). A subsidiary selling services under contract to named corporate customers issues the full invoice. Sales to an overseas parent are covered in consumption tax on cross-border sales.

The Six Required Fields: A Sample Layout to Check Your Template Against

A qualified invoice must show six items: issuer name and T-number, date, description, totals and rate by band, yen tax by rate, and customer name.

The table maps each item in Article 57-4(1), as listed in NTA Q&A question 54 (revised April 2024), to what the invoice should print and where a group template falls short.

Field on the invoice	Statutory item	What to print	Where a group template falls short
Issuer name and registration number (登録番号, toroku bango)	Item 1	The Japan entity's registered name and T plus its 13-digit corporate number	Group brand or HQ entity in the header; T-number field left blank
Transaction date	Item 2	Date of each supply, or the period a monthly invoice covers	Invoice date only, no supply date or period
Description	Item 3	What was sold, with reduced-rate items marked by a symbol and legend	A product code that does not identify the service
Total by rate, with the rate	Item 4	Subtotals for items at the statutory 10% and 8% rates, tax-exclusive or tax-inclusive, each labelled with its rate	A single grand total, or subtotals without the rate
Consumption tax by rate	Item 5	Yen tax for each rate	Tax summed from rounded lines, or shown only in the invoice currency
Customer name	Item 6	The customer company's name	A contact person or internal account number in the bill-to field

The fields are set in the issuing system; group ERP versus local accounting software sets out the trade-offs, and what the invoice system means for accounting software covers vendor checks. The yen tax feeds the output tax account; see consumption tax filing deadlines.

Invoices priced in a foreign currency

Every item may be in a foreign language or currency except the tax by rate, which must be in yen (Basic Circular 1-8-16, Q&A question 68). Conversion follows the corporate tax method, such as the mid rate (TTM) on the transaction date, or, where that is impractical at issue, a reasonable method used consistently. In the NTA's example, a USD 54 subtotal at a TTM of 115.21 becomes JPY 6,221, and JPY 6,221 x 10% = JPY 622.1, rounded to JPY 622.

Delivery notes and monthly invoices

The six items may be split across linked documents, such as delivery notes whose numbers are printed on the monthly invoice (Basic Circular 1-8-1, Q&A question 67). The tax by rate is then calculated on whichever document carries it.

Tax Per Rate and Rounding Once Per Invoice

Round the consumption tax once per tax rate on each invoice; rounding each line and then adding the results is not allowed.

Enforcement Order Article 70-10 and the NTA invoice system Q&A, question 57 (revised April 2024) leave the method (up, down or half up) to the issuer. A billing engine set up for per-line VAT rounding produces a different figure, by up to one yen per line, so test with an invoice that has many lines. The example takes three lines at 10%, rounded down.

Line	Tax-exclusive amount (JPY)	Tax at 10% (JPY)	Rounded per line (JPY)
Consulting, October	33,333	3,333.3	3,333
Implementation support	12,345	1,234.5	1,234
Travel time	8,888	888.8	888
Sum of rounded lines (not permitted)	54,566		5,455
One rounding for the 10% band (statutory)	54,566	5,456.6	5,456
Difference on this invoice			1

Choose one rounding method for all Japan invoices; switching between them makes the output tax ledger harder to reconcile.

Return, Discount and Rebate Invoices

An issuer that refunds, discounts or rebates a sale to a taxable business must issue a qualified return invoice unless the refund is under JPY 10,000.

The qualified return invoice (適格返還請求書, tekikaku henkan seikyusho) is required by Article 57-4(3). Its items, per the NTA invoice system Q&A, question 60 (revised October 2023), are:

1. The issuer's name and registration number.
2. The date of the refund, and the date of the original sale, which may be a period within the taxable period.
3. A description of the original supply, with reduced-rate items marked.
4. The refund amount, tax-exclusive or tax-inclusive, totalled by rate.
5. The tax on the refund, or the rate applied.

The threshold includes tax (Enforcement Order Article 70-9(3)(ii)) and is tested per invoice or receivable reduced, not per rate (NTA Q&A question 28). A customer that deducts a JPY 440 bank charge from a JPY 500,000 invoice needs no return invoice; a rebate of JPY 100 per unit totalling JPY 20,000 does. A rebate may be netted on the next sales invoice, either showing both sets of items or, if done consistently, net totals and net tax by rate (Q&A question 62). Check that the group credit memo template carries the T-number and the original sale date.

Correcting a Wrong Invoice

If an issued invoice contains an error in a required item, the issuer must give the customer a corrected qualified invoice and keep copies of both versions.

Article 57-4(4) and (5) apply to qualified, simplified and return invoices, including those sent as data. The NTA invoice system Q&A, question 33 (revised October 2023) accepts two methods:

• Full reissue: a document marked as a correction that repeats all six items with the error fixed.
• Correction notice: a document that identifies the original invoice and states the wrong and corrected figures.

An ERP cancel-and-rebill is a full reissue, so it works if the new document carries every item and refers to the invoice it replaces. Keep errors and commercial changes apart: a wrong tax amount or missing T-number is corrected, while a price cut agreed after the sale is a discount that needs a return invoice.

Issuing and Storing Electronic Invoices

Invoices may be sent by email, portal or EDI instead of paper, but the issuer must archive the data with integrity and search controls.

Article 57-4(5) allows this (Basic Circular 1-8-2). Copies are kept for seven years from the day two months after the end of the taxable period of issue, at the place of tax payment or the office handling the transaction (Enforcement Order Article 70-13(1), Q&A question 79). With a March year-end, an invoice issued on 15 October 2026 is kept from the following 1 June to 31 May seven years later. Paper invoices printed from the company's own system may be archived as data under the Electronic Books Maintenance Act (電子帳簿保存法, Denshi Chobo Hozon Ho), Article 4(2), with the system documentation kept alongside (Q&A question 80).

The storage rules for invoices sent as data come from the NTA invoice system Q&A, question 81 (revised April 2024). A printout meets the consumption tax rule only (Enforcement Regulation Art. 26-8(2)); for corporate tax, Article 7 of the Electronic Books Maintenance Act requires electronic transaction data, sent and received, to be kept as data (NTA Electronic Books Maintenance Act Q&A, electronic transactions, June 2025 edition).

Requirement	What the rules ask for	Legal basis
Form	As data (a printout is a consumption tax option only)	Enforcement Regulation Art. 26-8
Integrity (one of four)	Timestamp before sending; timestamp promptly after; a system that logs or blocks edits; or internal rules against unjustified edits, applied in practice	Electronic Books Regulation Art. 4(1)
System overview	Documentation of the system holding the data	Electronic Books Regulation Art. 2(2)(i)
Display and output	Equipment on site to show and print the data promptly	Electronic Books Regulation Art. 2(2)(ii)
Search	By date, amount and customer; range searches on date and amount; combined conditions	Electronic Books Regulation Art. 2(6)(v)
Partial search relief	Range and combined searches not needed if the data can be produced on a tax office request	Same provision
Full search waiver	No search needed if the data can be produced on request and either sales in the base period (two years earlier) were JPY 50 million or less, or printouts sorted by date and customer can be produced on request.	Same provision

The wider record rules are in paper and digital document rules in Japanese back offices.

FAQ

Does a qualified invoice need a company seal?

No. A company seal (角印, kakuin) is not among the Article 57-4(1) items listed in NTA Q&A question 54, so an invoice without one still qualifies. A seal on an invoice is a business custom, not a condition of the customer's credit.

Does the invoice have to show the customer's registration number?

No. Article 57-4(1) requires only the issuer's registration number, and item 6 asks for the customer's name alone. Whether the customer is registered does not change what the issuer prints.

Does the NTA publish its qualified invoice guidance in English?

The NTA's English consumption tax pages carry a guide titled Japan Invoice System Instructions, June 2024 edition. The invoice system Q&A, which holds the detailed answers on rounding, return invoices, corrections and storage, is published in Japanese.

Working with AQ Partners. Our Tokyo team provides customer invoicing administration, accounting software setup and monthly bookkeeping for foreign companies operating in Japan. Book a consultation to review your Japan invoice template.