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Japan

16 August 2017

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Yang Ho Kim

Deloitte Japan

Shin Tokyo Building
3-3-1 Marunouchi, Chiyoda-ku
Tokyo 100-8305
Japan

Tel: +81 3 6213 3841
Fax: +81 3 6213 3808
Email: yangho.kim@tohmatsu.co.jp
Website: www.deloitte.com

Yang Ho Kim, Deloitte Japan, is a Japanese licensed tax accountant and US chartered public account who is Deloitte's business tax services leader in the country. He has more than 26 years of experience in public accounting, serving many Japan-based and US-based multinational enterprises. He supports various clients in all types of national and international disputes and negotiates settlements with the tax authorities.

He has extensive practical experience in the taxation of various aspects of financial and international transactions and tax accounting issues. His specialties include international tax planning, structured finance, and inbound and outbound M&A.

He has also assisted many foreign-based private equity funds and sovereign wealth funds with advising on the various aspects of tax-efficient structuring alternatives.

From January 1997 to March 2001, he was assigned to the banking and securities group and Japanese services group in the Deloitte New York Office.

Further, Yang Ho is a frequent speaker at conferences and seminars on various structure finance related matters and is the author of numerous articles and publications in the field of international taxation such as entity classification, foreign tax credit and controlled foreign corporation (CFC) regimes.

He is a graduate of Keio University, Tokyo, where he earned a BA in economics. He also earned a Master of Science in taxation at Fordham University, New York.

He is a member of the American Institute of Certified Public Accountants and Japan Federation of Licensed Tax Accountant's Association.


Yutaka Kitamura

Deloitte Japan

Shin-Tokyo Building 5F
3-3-1 Marunouchi, Chiyoda-ku
Tokyo 100-8305
Japan

Tel: +81 70 3192 5611
Fax: +81 3 6213 3801
Email: yutaka.kitamura@tohmatsu.co.jp
Website: www.deloitte.com

Yutaka Kitamura, Deloitte Japan, has been taking a comprehensive approach to providing solutions for clients' matters by teaming up with law, tax and accounting professionals in order to facilitate better tax compliance for his clients for years. He provides one-stop services from tax planning to tax audit defence, requests for reconsideration and tax litigation and has experience of being engaged in court and tribunal cases where taxpayers have won.

He is an attorney at law admitted in Japan and the State of New York. He is also a certified public tax accountant.

Yutaka joined Deloitte Tohmatsu Tax Co in 2017 and works in the tax controversy team. Before this, he worked at EY (2012-13) and founded EY Law Co. as a law firm that became a Big 4 member firm for the first time in Japan (2013-17). Previous to this, he joined the Financial Services Agency (financial tax office, policy and legal division, planning and coordination bureau) as deputy director (2009-12) and was at Nagashima Ohno & Tsunematsu (2000-09). Between 2010 and 2015, he was a part-time lecturer at the Kyoto University Law School (tax case study).

He wrote many articles, including "Foreign Exchange Issues in International Taxation" (IFA Branch Report for Japan), "Cahiers de droit fiscal international" (Vol. 94b, 2009), and "The Application of the Japan-U.S. Tax Treaty to Trusts", 41 Tax Notes Int'l 577-588 (2006).


Daisuke Miyajima

PwC Tax Japan

Kasumigaseki Bldg 15F
2-5 Kasumigaseki 3-chome
Chiyoda-ku, Tokyo 100-6015
Japan

Tel: + 81 3 5251 2552
Email: daisuke.miyajima@jp.pwc.com
Website: pwc.com/taxcontroversy

Daisuke Miyajima is a partner in the international tax services (transfer pricing) group of PwC Tax Japan. During his more than 25 years at the firm, he spent several years on assignment with the transfer pricing group in the Washington DC and New York offices. In the transfer pricing area, Daisuke has provided advice towards numerous Japanese and foreign clients on their inter-company transactions with related parties and its effect on Japanese and foreign transfer pricing rules. He has also assisted in preparing studies for presentation to the appropriate tax authorities and has successfully defended several well-known Japanese and foreign companies in transfer pricing audits. He is also an expert in the area of competent authority negotiations and advance pricing agreements. While his experience includes clients in virtually every industry, he particularly specialises in the high-tech, automotive, entertainment, and luxury goods industries. Daisuke has also written extensively on the above areas in various publications and is a frequent speaker at seminars held by PwC and outside organisations. He has been chosen as one of the world's leading transfer pricing consultants in various publications. He also writes and is fluent in both Japanese and English.

Daisuke is also an associated member of the American Institute of Certified Public Accountants.


Jun Sawada

Deloitte Japan

Shin Tokyo Building
3-3-1 Marunouchi
Chiyoda-ku Tokyo
Tokyo, 1008305
Japan

Tel: +81 3 6213 3927
Fax: +81 50 3033 0434
Email: jun.sawada@tohmatsu.co.jp
Website: www.deloitte.com

Jun Sawada, Deloitte Japan, is a partner working in the transfer pricing group. After starting his career with Arthur Andersen in 1999, Jun has advised both foreign and Japanese multinationals on various transfer pricing and cross-border taxation issues. Before joining Deloitte Japan in October 2013, Jun worked with EY and White & Case.

Jun has represented clients in various discussions with the Japanese tax authorities. He has defended companies under audit, assisted companies in their negotiations with tax authorities to obtain advanced approval of their transfer pricing (through unilateral/bilateral APAs), and supported companies in domestic tax appeals. In particular, he has assisted clients in industries such as pharmaceuticals, medical devices, software, luxury goods and apparel, consumer products, high-tech, chemical, automotive, entertainment, and trading houses. Jun has also supported clients with their needs for assistance in compliance (transfer pricing documentation), establishing transfer pricing policies, and determining tax effective supply chains.

Having lived overseas for more than 12 years during his youth, Jun is bilingual in English and Japanese. Jun has contributed articles in Tax Analysts, International Tax Review, and several major Japanese tax magazines, and has also co-authored several books in Japanese regarding transfer pricing.


Ryann Thomas

PwC Tax Japan

Kasumigaseki Bldg 15F
2-5 Kasumigaseki 3-chome
Chiyoda-ku, Tokyo 100-6015
Japan

Tel: +81 (0)3 5251 2356 (Direct)
Email: ryann.thomas@jp.pwc.com
Website: pwc.com/taxcontroversy

Ryann Thomas is a partner in the transfer pricing group of PwC Tax Japan. Since she joined the firm in mid-2001, Ryann has worked exclusively in the transfer pricing area, assisting multinational corporations with compliance, transfer pricing audit defence, and advance pricing agreements (APAs). More recently, her work has expanded to cover the implementation and documentation of pricing policies for branches under the newly introduced AOA (authorised OECD approach) legislation for branch profit attribution.

While Ryann has been involved in transfer pricing projects for a variety of clients, she spends much of her time assisting inbound clients manage their Japanese transfer pricing issues. This includes working with inbound clients to develop transfer pricing policies for the Japanese market, as well as reporting on those policies under the Japanese documentation legislation. She also has significant experience in assisting clients with defending their transfer pricing in audits. This assistance covers not only technical issues raised in such audits, but also understanding and managing the Japanese audit process and, where appropriate, mutual agreement procedures.

Connected with her audit experience, Ryann has worked for many years on APAs, either at the conclusion of an audit process, or as a pre-emptive measure against a future audit challenge. This has involved not only bilateral agreements (some, including those in the financial services sector, of considerable complexity), but also successfully managing the unilateral process, where a bilateral agreement was not suitable for the taxpayer.

Prior to coming to Japan, Ryann worked as a barrister and solicitor in commercial and private litigation in New Zealand. Ryann has a Bachelor of Commerce and a Bachelor of Laws (Honours) degree from Auckland University, and a Bachelor of Arts degree from Massey University.


Hiroki Yamakawa

Deloitte Japan

Shin Tokyo Building 5F
3-3-1 Marunouchi, Chiyoda-ku
Tokyo 100-0005
Japan

Tel: +81 3 6213 3751
Email: hiroki.yamakawa@tohmatsu.co.jp
Website: www.deloitte.com

Hiroki Yamakawa, Deloitte Japan, is a partner of transfer pricing services and licensed tax accountant of Deloitte Tohmatsu Tax Co and a leader of the global tax controversy team and a board member.

Hiroki is also a member of the International Taxation Study Group, 21st Century Public Policy Institute, and Japan Business Federation. Also, he is a committee member of the international taxation study group, Japan Machinery Centre for Trade and Investment.

He currently provides services such as responses to tax investigations and tax-related litigation, mutual agreements, advance pricing agreements, international planning, etc.

Hiroki graduated from Keio University's faculty of economics in 1982. He completed the international tax programme at Harvard Law School in 1992, and was a visiting research fellow at Columbia University's School of International and Public Affairs, and at the same university's business school's center on Japanese economy and business.

He joined Deloitte Tohmatsu Tax Co in September 2014 after leaving his position as director of the large enterprise examination division of the National Tax Agency. During his 32-year tenure at the agency, he held key positions in the field of international taxation, such as director of the transfer pricing division of the Tokyo Regional Taxation Bureau, director (international examination) at the National Tax Agency, and director of the office of mutual agreement procedures at the same agency. In addition, Hiroki served as deputy assistant regional commissioner of the criminal investigation department and assistant regional commissioner of the second large enterprise examination department of the Tokyo Regional Taxation Bureau, director of the rulings and legal affairs division of the National Tax Agency, and director of the examination and supervision division of the judicial system department at the Ministry of Justice.

Besides authoring Transfer Pricing Rules (Zeimu Kenkyukai, 2007), Enforcement of Transfer Pricing Rules in Japan (Zeimu Kenkyukai, 1996), and International Tax Challenges for Large Corporations, a supplement to Monthly Kokusai Zeimu (Kokusai Zeimu Kenkyukai, 2014), Hiroki has contributed to many collective publications, such as a report by the Japanese branch of the International Fiscal Association. He also has much experience of public speaking and keynote addresses, including events organised by Nikkei, the American Chamber of Commerce in Japan, the European Business Council, and New York University School of Law.


Brajeshwar Banerjee
KPMG

Atsushi Fujieda
Nagashima Ohno & Tsunematsu

Yushi Hegawa
Nagashima Ohno & Tsunematsu

Akihiro Hironaka
Nishimura & Asahi

Michito Kitamura
PwC

Yuichi Komakine
KPMG

Takayuki Kozu
KPMG

Shigeki Minami
Nagashima Ohno & Tsunematsu

Toshio Miyatake
Adachi, Henderson, Miyatake & Fujita

Hisashi Miyatsuka
Nishimura & Asahi

Yuko Miyazaki
Nagashima Ohno & Tsunematsu

Eiichiro Nakatani
Anderson Mori & Tomotsune

Kuniaki Nomura
Nomura & Partners

Yo Ota
Nishimura & Asahi

Takashi Saida
Nagashima Ohno & Tsunematsu

Koichi Sekiya
EY

Kazuhiro Takei
Nishimura & Asahi

Shigekazu Torikai
Torikai Law Office

Edwin Whatley
Baker McKenzie

Hideyuki Yamamoto
Baker McKenzie






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