Shiseido Co. is under fire from tax authorities for allegedly failing to report ¥3.8 billion in income for a five-year period through March 2012 by pooling profits at a U.S. subsidiary, sources said.

Japan's top cosmetics brand is planning to dispute the allegation by filing a complaint and calling on Japan and the United States to hold consultations on its case to avoid double taxation, the sources said.

Even so, Shiseido paid a tax penalty of around ¥1.7 billion on Tuesday, they said. The amount included a charge for underreporting its income and local government duties.