Japan

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Japan

Masahiko Kobayashi

kobayashi.jpg

 

Deloitte Japan

Shin-Tokyo Building 3-3-1

Marunouchi Chiyoda-ku

Japan

Tel: +81-3-6213-3938

Fax: +81-50-3116-0190

Email: masahiko.kobayashi@tohmatsu.co.jp

Masahiko Kobayashi is a certified tax accountant and has been a partner of the transfer pricing consulting group of Deloitte Japan since July 2008. He has also been a leader of the firm's tax disputes resolution group.

Before joining Deloitte in 2006, he spent 26 years as a tax official in various departments of Japan's National Tax Agency (NTA), including the Tokyo Regional Taxation Bureau (TRTB), the National Tax College and local tax offices, as well as three years at the Ministry of Finance. In particular, he spent more than five years as a deputy director in the Office of Mutual Agreement Procedures (OMAP) in the NTA.

Through these roles, Masahiko gained significant experience in international tax, transfer pricing and advance pricing agreements (APAs). While in the OMAP, he dealt with a wide variety of cases between Japan and various foreign competent authorities. These included major European countries and some Asian developing countries. Most of the double taxation cases he participated in managed to reach agreement among the parties involved.

Since joining Deloitte, he has dealt extensively with transfer pricing disputes, including a case where a substantial amount of money was recovered for a foreign financial company through a tribunal procedure.

Other notable cases include: transfer pricing and APA cases in the pharmaceutical industry; transfer pricing taxation and APA cases on the global trading of financial derivative products; and permanent establishment taxation cases of foreign companies doing business in Japan, and those of Japanese companies doing business in foreign developing countries.

Masahiko is the co-author of All About Tax Audit in Japan (Seibunsha 2013) and Transfer Pricing and Tax Management (Seibunsha 2011). He is a member of the Japan Association of Tax Litigators and the Japan Tax Accounting Association.

deloitte.jpg



Akira Akamatsu

White & Case

Atsushi Fujieda

Nagashima, Ohno & Tsunematsu

Yushi Hegawa

Nagashima, Ohno & Tsunematsu

Akihiro Hironaka

Nishimura & Asahi

Michito Kitamura

Nishimura & Asahi

Toshio Miyatake

Adachi, Henderson, Miyatake & Fujita

Hisashi Miyatsuka

Nishimura & Asahi

Yuko Miyazaki

Nagashima, Ohno & Tsunematsu

Yo Ota

Nishimura & Asahi

Koichi Sekiya

EY

Gary Thomas

White & Case

Hideyuki Yamamoto

Baker & McKenzie

more across site & shared bottom lb ros

More from across our site

The network’s tax service line grew more than those for audit and assurance, advisory and legal services over the same period
The deal is a ‘real win’ for US-based multinationals and its announcement is a welcome relief, experts have told ITR
Tom Goldstein, who is now a blogger, is being represented by US law firm Munger, Tolles & Olson
In looking at the impact of taxation, money won't always be all there is to it
Australia’s Tax Practitioners Board is set to kick off 2026 with a new secretary to head the administrative side of its regulatory activities.
Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation
The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes
Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs
The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Awards
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
Gift this article