"If you don't have a registration number, could you give me a discount for that?"—This is a conversation you might encounter from business partners, triggered by changes to the invoice system's transitional measures in October 2026.
There is a transitional measure that allows a certain percentage of input tax deduction even for purchases from parties who are not eligible invoice-issuing businesses, such as tax-exempt businesses. According to the National Tax Agency's guidance, it is 80% until September of Reiwa 8 (2026), and 70% from October of Reiwa 8 (2026) to September of Reiwa 10 (2028). Please check the National Tax Agency's guidance for the percentage after that. As the deductible percentage decreases, the burden on the ordering party increases, so cases where business conditions are proposed to be revised are also anticipated.
The Fair Trade Commission's "Q&A on the Invoice System" explains that unilaterally notifying tax-exempt businesses that they will lower transaction prices unless they become taxable businesses, or that they will terminate transactions if they do not comply, may be problematic under the Antimonopoly Act and the Subcontracting Act (formerly the Subcontracting Law). In transactions subject to the Subcontracting Act, the mere fact that a supplier is a tax-exempt business is not considered a legitimate reason for reducing payment.
The key point is whether it is "unilateral." It does not prohibit both parties from consulting and revising conditions based on mutual agreement. Additionally, whether the Subcontracting Act applies depends on conditions such as the content of the transaction and the scale of the parties involved.
- When, from whom, and in what form (oral/email/written) the reduction proposal was made
- The originally agreed compensation amount and the quotation, contract, or purchase order that served as its basis
- If discussions on revision were held, the exchanges and agreed terms
If it feels like a unilateral notification, the best approach is to first keep records, and then consult with the Fair Trade Commission or other relevant agencies as needed. This is a calmer way to respond.
Crewbook's work-for-hire contract template includes a clause stating that the ordering party (Party A) will not unilaterally reduce compensation solely on the grounds that the contractor (Party B) is not an eligible invoice-issuing business. If you exchange this one clause at the time of contract, it will serve as a basis when a reduction is proposed later. By organizing quotations, contracts, and invoices for each project and confirming them with electronic signatures, records of "when and under what conditions agreement was reached" are also preserved. Contracts, invoices, and electronic signatures are available from the Free plan (¥0, up to 3 projects).
→ Full text of the explanatory article: https://crewbook.jp/blog/invoice-unilateral-discount
→ Try Crewbook: https://crewbook.jp/?utm_source=tsukutta&utm_medium=article
※This article is information provided by Crewbook. It includes introduction of our own services.
This article is general information provision, and individual judgments should be confirmed with specialists such as lawyers and tax accountants, or at the Fair Trade Commission and other relevant agencies. The content of the system is as of the time of creation.
