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Masahiko Kobayashi



Deloitte Japan

Shin-Tokyo Building 3-3-1

Marunouchi Chiyoda-ku


Tel: +81-3-6213-3938

Fax: +81-50-3116-0190


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.


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