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Japan

Masahiko Kobayashi

Deloitte Japan

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

Tel: +81 3 6213 3938
Fax: +81 50 3116 0190
Email: masahiko.kobayashi@tohmatsu.co.jp
Website: www.deloitte.com

Masahiko Kobayashi is a certified tax accountant and has been a partner of the transfer pricing consulting group of Deloitte Tohmatsu Tax since July 2008. He also has 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 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 taxation and APA cases in the pharmaceutical industry; transfer pricing taxation and APA cases on global trading of financial derivative products, and PE taxation cases of foreign company doing business in Japan, and those of Japanese company 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.



Akio Miyamoto

PwC

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

Tel: + 81 3 5251 2337
Email: akio.miyamoto@jp.pwc.com
Website: pwc.com/taxcontroversy

Akio Miyamoto is a leading transfer pricing specialist in Japan with more than 20 years' experience in the field, beginning in 1991, which was around the time Japan commenced transfer pricing examinations, following the introduction of transfer pricing legislation in 1986.

Given Japan's robust transfer pricing audit environment, and the wide use of advance pricing agreements in Japan, he has been extensively involved in transfer pricing audit defence cases, competent authority negotiations, advance pricing agreements, transfer pricing documentation projects and transfer pricing risk assessment reviews. As one of the first transfer pricing professionals in Japan, Miyamoto has an in-depth knowledge of Japanese transfer pricing practice and procedures.

He has assisted foreign and Japanese multinational clients in numerous industries, with particular emphasis in the medical device, pharmaceutical and luxury goods industries, which he has been involved with since the time the Japanese tax authority began to focus on these industries. He also has significant experience in the consumer goods and technology industries.

Akio has dealt with a wide variety of transfer pricing and transfer pricing related issues, including business restructurings, profit attribution to permanent establishments, treaty application to transfer pricing disputes and commissionaire structures. He has also participated as a speaker at various transfer pricing conferences throughout the world.

Akio joined the Tokyo office of Price Waterhouse in 1979 and spent four years working in Price Waterhouse's Toronto office. His career began in audit, and he was heavily involved with both Japanese and non-Japanese multinationals. He moved to transfer pricing in 1991, and has been leading the Japan firm's transfer pricing practice since then. Akio has been a partner since 1995.

Akio is a licensed Japanese certified public accountant and a licensed Japanese certified public tax consultant.



Toyoharu Nakamura

PwC

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

Tel: + 81 3 5251 2335
Email: toyoharu.nakamura@jp.pwc.com
Website: pwc.com/taxcontroversy

Toyoharu Nakamura began his career as a tax officer of the Tokyo Regional Taxation Bureau (TRTB) in 1973. In 1990, having experienced numerous international examinations at the TRTB, he was appointed as chief of the international examination section of the National Tax Agency (NTA) engaged in planning and directing examinations for multinationals conducted by the Regional Taxation Bureaus.

In 1992, Nakamura was appointed as deputy director at the Office of International Operations, the Commissioner's Secretariat of the NTA. While mainly engaged in competent authority negotiations, he was also actively involved in OECD-CFA work programmes, and made significant contributions to the revision of the OECD's transfer pricing guidelines.

Nakamura's expertise in the transfer pricing area is especially noticeable in the field of competent authority negotiations. In 1992, he arranged the first collaborative research on transfer pricing focusing on the characteristics of Japanese companies' business management, before heading the first competent authority negotiations between Japan and Australia. The following year, he concluded the first competent authority negotiations between Japan and the US using the profit split method. In 1994, he settled the first advanced pricing agreement involving the hybrid approach between Japan and the US. In addition, in 1995, he successfully concluded the first multilateral advanced pricing agreement among three different jurisdictions.

From 2001 to 2002, Nakamura worked as an adviser to the OECD in the education of senior Eastern European and Chinese tax officials of Ministry of Finance or National Tax Agency on tax treaties and international tax avoidance issues, including transfer pricing.

Nakamura joined the transfer pricing consulting group of PricewaterhouseCoopers, Tokyo in 2002, and is now a partner. He is a licensed Japanese certified public tax consultant. He holds a BA in law from Chuo University and passed through the postgraduate school of Keio University majoring in tax litigation.



Jun Sawada

Deloitte Japan

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

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

Jun is a partner of Deloitte Japan's transfer pricing group. After starting his career with Arthur Andersen in 1999, Jun has been advising both foreign and Japanese multinationals on various transfer pricing and cross-border taxation issues. Before joining Deloitte Tohmatsu Tax in October 2013, Jun worked with Ernst & Young 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 (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 International Tax Review, Tax Analyst, and several major Japanese tax magazines, and has also co-authored in several books in Japanese regarding transfer pricing.



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