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 2025

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

Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year
The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies
Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Gift this article