I would also use caution on how you describe their function verbally, and in writing or documentation. The more you treat them as a remote disconnected entity the more risk created in terms of control. You must have control over them absolutely so dont call them "The Japanese R&D entity" I would use "Our R&D unit, with primary offices in Japan" or not even mention Japan unless thats important somehow. You arent lying - you are communicating structure and integration. As an auditor if I heard "XXX in Japan" I would think "separate governance?" If they are part of your organization you could just list "R&D" Its not deceitful and perfectly describes their roles integrated into you QMS.