Japan

Partner

PwC Legal Japan

Tokyo

+81 (0)3 5251 2600

michito.kitamura@pwc.com

www.pwc.com/jp/en/about/member/legal/consultant-profile/michito-kitamura.html

Languages: Japanese, English

Bar admissions: Tokyo Bar Association

Michito Kitamura is a partner of PwC Legal Japan. He joined PwC in 2016. Before that, he started his career as a C.P.A at Arthur Andersen and then he was working for the largest law firm in Japan for 15 years. He graduated from International Tax Program of New York University.

Michito Kitamura has successfully defended his clients in the tax audits (e.g. defended M&A tax matters with potential huge impact for a famous Japanese pharmaceutical company in 2018).

He represented tax disputes and litigations including the case regarding entity cclassification of foreign entities, tax treatment of debt-equity-swap, deferral treatment on hedge transaction and application of CFC (anti-tax haven) rule.

Audit defence, Dispute resolution, Litigation, Controversy management, Tax consulting

Investment management, Pharma and life sciences, Tech and telecoms

Tokyo Bar Association, Member of JICPA

LL.M. in International Taxation, New York University School of Law, 2007

LL.M. with Distinction and Dean's List, Georgetown University Law Center, 2006

B.C., Keio University, 1994

Partner

Nagashima Ohno & Tsunematsu

Tokyo

+81 3 6889 7177

minami_shigeki@noandt.com

www.noandt.com

Languages: Japanese and English

Bar admissions: Admitted to the Bar in Japan, 1997

Shigeki Minami's practice focuses on various forms of mergers and acquisitions, including statutory reorganizations, leveraged buy-outs, management buy-outs, joint ventures, strategic alliances and private equity investing. He is recognized as a specialist, especially in handling M&A matters from the aspect of tax affairs.

Mr. Minami is also an expert in general tax law matters. He regularly represents major Japanese and foreign companies in tax audits, tax disputes and competent authority procedures (including APA and MAP) with the Japanese and foreign tax authorities, and he has litigated tax cases in the National Tax Tribunals and the Japanese courts.

Mr. Minami serves as the Chair of the Asia-Pacific Regional Committee of the International Fiscal Association (IFA), and as a member of the Practice Council of International Tax Program, New York University School of Law.

• General Corporate

• Mergers and Acquisitions (M&A)

• Private Equity/Venture Capital

• Tax Advice and Planning

• Tax Disputes

• Wealth Management/Business Succession/Inheritance

• The University of Tokyo (LL.B.), 1994

• Admitted to bar in Japan, 1997

• New York University School of Law (LL.M. in Corporate Law), 2002

• New York University School of Law (LL.M. in Tax Law), 2003

• Masuda & Ejiri, New York, 2003-2004

• Visiting Professor in tax law, LEC Graduate School of Accountancy, 2005-present

• Adjunct Lecturer in civil law seminar, The University of Tokyo2006, 2008 and 2009

• Nagashima Ohno & Tsunematsu, 2007-

• Partner, Nagashima Ohno & Tsunematsu, 2009-present

• Adjunct Lecturer in law and economics, The University of Tokyo, 2010-present

• Visiting Professor in Tax Law, Graduate School of Law, Kobe University, 2016-present

• Adjunct Lecturer in Tax Law, Sophia Law School, 2017-present

PwC Tax Japan

Tokyo

+81 3 5251 2552

daisuke.miyajima@jp.pwc.com

pwc.com/taxcontroversy

Daisuke Miyajima is a partner and leader of the international tax services (transfer pricing) group of PwC Tax Japan. During his more than 25 years at the firm, he spent several years working in the transfer pricing group in Washington DC and New York. 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.