Accounting during an Amazon suspension: records for Japanese tax returns and year-end accounts

When an account is suspended, it's natural to focus on the reinstatement appeal, but how you handle held sales proceeds and FBA inventory also affects your books, tax return, and year-end accounts. This article is for sellers (sole proprietors and companies) whose account is currently suspended. It covers how to sort out unpaid money, what records to pull and how to keep them, and how to schedule the work by working backward from your filing deadline.

Accounting doesn't stop when your account is suspended: the basic premise

Under the Amazon Services Business Solutions Agreement (BSA), obligations related to transactions entered into before termination, and liabilities arising before or as a result of termination, remain the seller's responsibility even after the agreement ends. Responsibility for collecting, reporting, and paying taxes lies with the seller (except to the extent Amazon has agreed to collect them on the seller's behalf through a tax calculation service), and Amazon has no obligation to determine or file consumption tax (Japan's VAT-equivalent) on the seller's behalf.

Even while suspended, the basic flow doesn't change: you still total that year's sales and expenses and, if a return is required, file it by the deadline (bookkeeping and retaining records are required regardless of whether filing is required).

This article is based on Amazon Help content and National Tax Agency materials we were able to confirm as of September 2026. It is a general overview of the information, not tax advice for your individual situation. Please confirm the specific treatment with a tax accountant. Seller Central menu names differ between the old and new screens and can change, so please check them against what you actually see. Amazon does not officially state which screens remain viewable while an account is suspended, and this can vary depending on the account's status.

Sorting unpaid money into three categories

Based on Amazon Help, unpaid amounts generally fall into three categories.

Category	What it mainly covers (summary of Help content)	Where to check
Pending transactions	Sales proceeds held for a set number of days from the delivery date (7 days by default) in case of refunds. Referral fees and FBA fees for the order are held along with it	"Pending transactions" under Payments, or "Manage Transactions" on the new screen
Account-level reserve	Amounts held for reasons such as unresolved A-to-z Guarantee claims, chargebacks within the past 90 days, or an account under review. Multiple reasons can apply at once	"Account level reserve" in the Payments report list
Sales proceeds held for risk	When Amazon determines there is risk, the full unremitted balance at the time of the hold is generally held for 90 days, and this can be extended. If Amazon determines the account was used for a purpose such as a policy violation, funds are held until no wrongdoing is confirmed (a hold can in some cases be permanent)	Notifications, Payments reports

Sales from the last few days before suspension may already show as pending transactions at the time of suspension. For how to confirm the reason for a hold and the process for requesting payment, see how to check sales proceeds after suspension.

Held amounts can change after the fact

Amazon explains that the amount held for risk is not fixed at the suspension-date balance; it can change through offsets such as returns and refunds, A-to-z Guarantee claims, the cost of returning or disposing of inventory, and unpaid fees. If fees and refunds exceed sales, the balance can go negative, which may require a charge to your registered credit card or repayment by wire transfer, so review it at the end of every month.

Recording "amount deposited" as "sales" can throw off your books

Amazon advises using the Transaction report in the report repository to check revenue for a given period, and Date Range Reports ("Payments summary" on the new screen, formerly called "past settlement information" — 過去の決済情報) to check cash actually received. The former is based on the date recorded to the account and includes pending transactions, while the latter includes only transactions for which payment has been executed, so the totals and the deposited amount may not match.

Under general tax rules, income from a sole proprietor's product sales is generally recorded in the year the goods were delivered (National Tax Agency Income Tax Basic Directive 36-8). Companies likewise record revenue in the fiscal year that includes the delivery date (Corporation Tax Act Article 22-2). A sole proprietor's necessary expenses are also generally judged by whether the obligation was fixed within that year, not by whether payment was made. That said, there are exceptions that allow recording on a cash basis, such as blue-return filers whose combined real estate and business income for the year before last was 3 million yen or less and who have filed a notification for the "special calculation of income on a cash basis." Check with a tax accountant which applies to you.

Also, dates in period reports reflect the date recorded, which may not match the ship date or order date. For orders that straddle your fiscal year-end, cross-check against shipping and other records, decide which date to use as your standard (ship date, delivery date, etc.), and apply that same standard every year (Income Tax Basic Directive 36-8-2). It helps to keep the two separate: your books follow the recording-date standard, and your cash flow follows the deposit-date standard.

Records to save while suspended, and where to get them

Since what you can view may change, save what you can while you still can access it. The main documents and their constraints are as follows.

Document	What it shows	Constraints when retrieving it
Date Range Reports	Summary (PDF) shows an overview of revenue, expenses, and taxes; Transaction (CSV) shows details of recorded transactions	Up to 365 days per request. Can take up to 3 hours to generate
Settlement report	Details of transactions paid out for each settlement period	The current settlement period cannot be pulled. Expires 90 days after creation
Transactions (old screen)	Breakdown of fees and adjustments per transaction	Only the past 24 months are viewable
Fee statement / Amazon seller fee charge invoices	Qualified invoices and qualified return invoices for Amazon fees	PDF only. One line per month
Inventory ledger report	FBA inventory: opening quantity, changes from receipts, sales, returns, disposals, losses, etc., and closing quantity	Can be pulled back up to 18 months
All Orders Report / Historical order reports	Order records (do not include buyer information)	All Orders is download-only. Historical orders require Transactions edit permission

STEP 1. Generate Date Range Reports month by month

Under "Payments" > "Report Repository," generate a "Summary report (PDF)" and a "Transaction report (CSV)" for each period set to "Month" (the 1st through the last day). Since the CSV is UTF-8, import it in Excel via Data > Get Data > From Text/CSV.

STEP 2. Save settlement reports for each settlement period

Confirm actual deposits using the settlement report for each settlement period (generally every 14 days). Get it from "past settlement information" (過去の決済情報) on the old screen, and move it somewhere safe promptly, since it expires 90 days after creation. Reconcile each one against your bank's deposit records and keep a list of settlement periods that haven't been paid; this list is also useful when you contact Amazon. For what to say in such an inquiry, see what to confirm with the Payments team.

STEP 3. Download fee invoices month by month

Invoices for referral fees, FBA fees, and the like are available under "Reports" > "Tax Document Library." Download the "Fee statement" (qualified invoice) and the "Amazon seller fee charge invoice" (qualified return invoice). Amazon's invoice-system FAQ explains that a taxable business needs to keep these invoices to claim the input tax credit for FBA fees. It also states they can be downloaded for up to 10 years, but since the handling during or after suspension isn't specified, get them every month. Invoices for advertising costs may be issued elsewhere, so check the advertising management screen as well.

STEP 4. Line up inventory, reimbursement, and order records

Save the inventory ledger report covering the month that includes your fiscal year-end as early as possible. Reimbursements for lost or damaged inventory appear in refund reports and in Payments transactions (e.g., "FBA inventory reimbursement"). Get FBA and seller-fulfilled orders from the "All Orders Report" (download-only), which can be filtered by order date or update date. Orders older than two years may not appear in the All Orders Report, so use the "Order Reports" > "Historical order" tab under "Orders" instead (follow what's shown on screen for the available range). To back up your sales history, see also preparing to substantiate your sales history.

When a document can't be pulled from the screen

If a report won't open or can't be regenerated, standard accounting practice is to supplement it with records from outside Amazon. Here's what can substitute for what:

What you need to confirm	Substitute document
Actual deposits	Bank account statements
Purchases and cost of goods	Supplier invoices and delivery notes
Circumstances of suspension/hold	Notification emails from Amazon

You can inquire about a held balance through the contact channel listed in the notification or Help content. Don't estimate missing figures on your own; bring a list of supporting documents to a tax accountant instead.

How to keep records: statutory retention periods and electronic data

Retain documents based on the statutory retention period under tax law, not the period Amazon lets you retrieve them. The main retention periods are as follows (based on National Tax Agency materials).

Category	Books	Documents
Sole proprietor (blue return)	7 years	Closing-related documents: 7 years. Documents related to cash and deposit transactions: 7 years (5 years if business income plus real estate income for the year before last was 3 million yen or less). Other documents such as invoices and delivery notes: 5 years
Sole proprietor (white return)	Books recording income and expenses: 7 years	Inventory lists, invoices, receipts, etc.: 5 years
Company	7 years from the day after the filing deadline for the final tax return (10 years for fiscal years with a net operating loss, etc.)	Same as books

For sole proprietors, the count starts from the day after March 15 of the year following the year in which the books were closed or the documents were created/received. Regardless of whether you are a sole proprietor or a company, invoices and similar documents retained by a taxable consumption-tax business for the input tax credit also require 7 years of retention.

Keep downloaded data as electronic data

Since January 2024 (Reiwa 6), invoices, receipts, and similar documents received as electronic data must be retained as electronic data, subject to certain requirements (electronic transactions under the Electronic Books Preservation Act). According to the National Tax Agency's Q&A, PDFs and similar files downloaded from a website also count as electronic transactions, and the point at which the document became viewable on the site is treated as the time of receipt — so not having downloaded it does not exempt you from the retention obligation. Even if you download items in bulk, they must be retained within the year that the transaction date falls in.

The requirements are generally three: measures to prevent tampering, having a display and other equipment available, and being able to search by "date, amount, and business partner." Preventing tampering is addressed through measures such as establishing and following internal rules on preventing correction and deletion; a file-naming convention alone does not satisfy this.

The search requirement can also be satisfied by naming files consistently and organizing them into folders. In addition, businesses such as those whose sales in the base period were 50 million yen or less are exempt from the search requirement itself, as long as they can respond to a request to download the data during a tax audit. An example file name is shown below.

When importing into accounting software, the treatment of pending transactions and reserves can differ by system, so cross-check the totals against your Date Range Reports and keep the original reports separately as well.

Monthly routine while suspended: what to check at month-end

Even while suspended, refunds, fees, and inventory returns keep changing the numbers, so check the following at the end of each month.

Keep a note of the results once a month. What follows is not an actual case, but a sample of how you might write it up.

The monthly subscription fee is treated differently for "suspended" versus "Vacation mode"

Amazon Help explains that the Professional selling plan's monthly subscription fee is not charged for months an account is blocked or suspended, but is charged during periods in Vacation mode. You can confirm whether it was charged in Payments transactions (transaction type "Service Fee") or in the fee statement. Other fees, such as inventory storage fees, are not covered by this exemption, so check the statement for those.

Working backward from your fiscal year-end and tax return

The main deadlines are as follows.

Category	Closing date	Main deadline
Individual income tax	December 31	March 15 of the following year (the filing period generally starts February 16)
Individual consumption tax	December 31	March 31 of the following year
Corporate income tax and consumption tax	Last day of the fiscal year	Within 2 months of the day after the fiscal year-end (both can be extended if you have applied for the filing-deadline extension)

Here is a rough schedule for working backward (one example).

1. 1–2 months before fiscal year-end: decide whether to return, keep, or abandon ownership of FBA inventory, and submit the necessary request (if you've received a notice requiring removal, prioritize that notice's deadline over your fiscal year-end)
2. Right after fiscal year-end: use the inventory ledger report together with any inventory on hand to fix the year-end quantity by location, and confirm unit costs from supplier invoices and delivery notes
3. The month after fiscal year-end: gather reports and fee statements through the closing month, and record the three categories of your balance
4. Up to a month before your filing deadline: bring any points that need judgment, along with supporting documents, to a tax accountant

Record year-end inventory broken down by location

Requests to return or abandon ownership of inventory are generally handled within 10–14 business days, but this can take 30 days or more from October through December or during other busy periods. If you submit the request right before your fiscal year-end, inventory tends to be split across "FBA warehouse," "in transit," and "on hand," so record the physical-count quantities by location and keep the inventory ledger and the content of the return request as supporting evidence. Since a physical count also needs a value, tie each SKU back to supplier invoices and delivery notes, and check the valuation method with a tax accountant.

Under the BSA, if Amazon has notified you that removal is required — for example due to account suspension — and you do not give instructions to return or dispose of the inventory within 30 days (or the period set by policy), Amazon may dispose of the inventory. For inventory a seller requests to dispose of (abandon ownership of), ownership also transfers to Amazon or others at no cost. For products suspected of a policy violation, you must first resolve the issue in "Account Health" before you can create a return request. Automatic removal settings (enabled by default) and the expiration of the unsellable-inventory holding period (30 days) can also trigger returns or disposals you didn't request. Check the inventory ledger's "Disposed" and similar changes month by month, and record the quantity, date, and circumstances separately for any inventory disposed of or abandoned.

A drop in this year's sales doesn't necessarily mean consumption tax isn't required

Consumption tax liability is generally determined by taxable sales in the base period (the year before last for a sole proprietor, or the fiscal year before last for a company with a one-year fiscal year); you're exempt if that figure is 10 million yen or less. However, you are not exempt if, among other things, you are registered as a qualified invoice issuer, or if taxable sales in the specified period (January–June of the previous year for a sole proprietor) exceed 10 million yen (this can also be judged using the amount of salary payments). Note that Amazon points out that domestic Japanese sales outside Amazon.co.jp are also included in taxable sales.

Points to check with a tax accountant rather than decide on your own, and things not to do

The following points can't be fully resolved from official materials alone, so gather your documents and check with a tax accountant.

Things not to do

• Deciding on your own not to record something as sales "because it hasn't been paid": as a general rule, the recording date is not the payment date (exceptions such as the cash-basis special treatment are noted above).
• Stopping bookkeeping or filing because of the suspension: if a tax audit asks you to produce your books and you can't, or if the recorded sales figure is markedly lower than it should be, there are measures that add a 5% or 10% surcharge to the penalty for underreporting or failure to file.
• Rewriting books or documents to make the numbers match: investigate the reason for any discrepancy and record it instead. A document altered to no longer match the facts can become a serious problem, both in a tax audit and in any appeal to Amazon.
• Creating a new account to keep selling: creating a new account to get around a suspension is a violation of Amazon's terms, so don't do it. The proper process is covered in the full picture from suspension to reinstatement request.

An accounting check before you consider closing or winding down the account

Suspension and account closure are different things, and suspension does not mean going out of business (see the difference between suspension and closure). Amazon Help states that once an account is closed, you can no longer log in to your selling account at all, cannot view your order history, respond to refunds or A-to-z Guarantee claims, and cannot reactivate it. You also cannot close an account if it's been less than 90 days since your last sale, or if the balance is not zero.

For how to wrap up unprocessed orders and remaining inventory, see preparing to close a seller account. If you're closing the business itself, procedures such as the notification of business opening/closure for a sole proprietor and the "notification to discontinue blue-return filing" may apply, and if you're a taxable consumption-tax business or registered as a qualified invoice issuer, related consumption-tax notifications also come into play. Since filing deadlines can be revised, check the latest National Tax Agency pages and a tax accountant.

Frequently asked questions

Q. Is a tax return still required for a year when there's almost no income because the account was suspended?

A. Suspension alone does not remove the requirement to file. If you were selling for part of the year, you still need to total that year's income and expenses. Under a blue return, you can carry a loss (net operating loss) forward for up to 3 years, but this requires continuing to file returns, so avoid letting your filing history lapse. Consumption tax is determined based on factors like sales two years prior and whether you are registered for invoices. Check whether filing is required with a tax accountant or the tax office.

Q. Refunds and fees pushed my balance negative while suspended, and my card was charged. How should I record this?

A. Check the breakdown in Payments transactions — refunds, refund fees, return fees, and so on — along with any "Unremitted" indicator, match each one against your card statement or wire transfer records, and save them. Check with a tax accountant which account to record them under.

Q. The figures on my fee statement and Payments report don't match.

A. Amazon explains that the fee statement is based on the actual transaction date while the Payments report is based on the payment date, so they can differ. Check the breakdown in Payments transactions and record which month the difference falls in.

Q. What should I bring when I consult a tax accountant?

A. It helps to bring the suspension notice, your month-end notes, Date Range Reports, settlement reports together with bank deposit records, fee statements, the inventory ledger, and records of returns/disposals. Also write down any points you're unsure about.

Summary

Even after an account is suspended, the record of past transactions and your filing responsibilities don't go away.

• Sort unpaid money into three categories, and record the amount and reason at the end of each month
• Keep your books on the recording-date standard separate from your cash flow, which follows the deposit-date standard
• Save reports, fee statements, and the inventory ledger as electronic data while you can still access them
• Work backward from your fiscal year-end and filing deadline, and settle FBA inventory returns and physical-count quantities/values early
• Consider closure only after gathering your records, and check the treatment of held funds and disposed inventory with a tax accountant

Getting your records in order alongside your reinstatement appeal means you won't be scrambling when it's time to close your books or file your return.

*This article provides a general explanation. The appropriate response in individual cases depends on the circumstances.

Further reading

Switching Amazon selling plans from Professional to Individual: fees and checks before changing Read article → Checking funds after an Amazon suspension: holds, disbursement requests and video interviews Read article → Preparing to close an Amazon seller account: outstanding orders, inventory and payments Read article →