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

As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals
Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses
Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness
Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
Gift this article