The tax and transfer pricing group offers a full range of domestic and international tax planning, structuring, controversy and economics services to multinational clients with respect to Japan, and to Japanese businesses seeking tax advice in foreign jurisdictions. The tax support network is comprised of dedicated Japan-qualified lawyers (bengoshi), certified public accountants, tax attorneys (zeirishi), US-qualified tax lawyers and economists. Key professionals include partner Edwin Whatley, who heads the tax group, and Ryutaro Oka, who is the principal tax advisor.
Details of the firm’s clients and recent work remain confidential.
The team at Deloitte Tohmatsu Tax maintains a strong reputation in corporate tax services, international tax strategies and reorganisation consulting. In addition, the firm’s other legal-related services involve corporate, M&A, tax controversy and labour and employment. Its clients include both Japanese and foreign multinational companies. It has developed its international network by deploying tax professionals to 10 jurisdictions to meet clients’ needs.
A recent example of the firm’s work included providing tax and financial strategy consulting services to local family companies in the shipping industry. One team member was stationed at the client and supported management succession to the next generation.
The team added five new partners in during the research period to strengthen the tax practice. One of the new partners, Paul Cherrone worked at KPMG Tax Japan before joining the team.
The tax team offers a range of services in Japan including international and domestic tax restructuring, supply chain remodeling, disputes related to customs duties and consumption tax for multinational clients. It regularly advises significant clients including Fortune 500 companies. It has the capability to deal with complex matters because of the size and expertise of its team. Keitaro Uzawa is the key Of Counsel in the team.
Details of the firm’s clients and recent work remain confidential.
Client feedback
“Always able to pick up the key points of discussion and give advice before going to the tax authority.”
The EY tax team consists of more than 900 tax professionals across five offices. It offers services in all tax disciplines, including business tax, indirect tax, international tax, transactional tax and people advisory services. With its global network resources the team supports integrated cross-border services. In addition, the transfer pricing team has dedicated professionals assisting clients with investment matters with transfer pricing management.
One of the case studies showed that the transfer pricing team, indirect tax team, and international corporate tax advisory team jointly assisted a client with tax restructuring for its connected car business. Work included providing summaries of the tax implications in major countries such as the US and Canada and accomplishing a business transformation in the automobile industry.
The tax practice in KPMG is comprised of more than 700 tax professionals, with a total of 53 partners in Tokyo, Osaka, Nagoya, Hiroshima and Fukuoka. It provides services including financial services, M&A, and real estate investment. In addition, it specialises in customs and VAT practice. It utilises its technology to strengthen the control and visibility of compliance, tax positioning and reporting.
During the research period, the team acted as an advisor for the Ministry of Economy, Trade and Industry and conducted a comprehensive analysis of BEPS 2.0 legislation and digital taxes. The work included conducting analysis and a study on the future of the international taxation system in Japan.
The team at Nagashima Ohno & Tsunematsu has a strong capability in handling tax litigation matters. Its practice covers general corporate tax, indirect and transactional tax. It has six partners dedicated to tax matters, many of whom are tax lawyers exclusively. Shigeki Minami is one of the key partners in the team. Shigeki focuses on M&A and deals with general tax matters.
The team recently successfully represented NGK Insulators before the Tokyo High Court in a transfer pricing litigation that involved ¥14 billion. The work included requesting cancellation of a tax adjustment administered by the Japanese tax authority. The Tokyo High Court agreed with the team’s argument and nullified most of the adjustments in favour of the client.
Two special advisors Mamoru Toba and Hiroshi Kaneko left the firm during the research period.
Nishimura & Asahi has a strong practice in the tax litigation area. The team consists of Japanese lawyers, foreign lawyers, tax counsel and other professionals across 18 offices. Its practice also covers all aspects of international and domestic business and corporate activities, including M&A transactions, group restructurings, financing arrangements, the development of financial products and other complex transactions. Partner Yo Ota is the lead of the tax group.
One of the case studies showed that the team continues to assist Jinba TMK with ongoing tax litigation. It represents the client in the dispute that involved consumption tax before the Tokyo District Court.
The team welcomed Tetsuo Kabe as of counsel during the research period. Prior to joining Nishimura & Asahi, Tetsuo worked as a special advisor to the Minister of Finance.
Tokyo Kyodo Accounting Office is an accounting firm based in Japan, holding correspondent firm status with RSM International. The firm comprises 336 members, delivering a broad range of services including M&A, business restructuring, wealth management, transfer pricing, and indirect tax. It has strong capabilities across diverse industry sectors such as banks, security firms, and investment funds. Kazuhiko Suda is an incumbent partner for the firm’s business restructuring service line.
In a recent case study, the firm assisted a Japanese company in a merger and acquisition transaction by providing tax due diligence services. As the acquisition involved the client’s subsidiary in Thailand, the firm collaborated closely with a local accounting office in Thailand to conduct the due diligence process.
The firm recently hired Yutaro Hirata as supervisor.
Withers Japan Zeirishi Houjin’s tax team was established in 2015. It offers domestic and international business tax strategies and advice services, covering areas of cross-border transactions, tax compliance, M&A and investment funds. Eric Roose led the Japan office and Withers’ International Corporate Tax practice in Asia.
The team led by Eric Roose recently served as a lead tax counsel and advised the Pacific Alliance Group on the fund structure of PAG REN I fund. This cross-border matter involved jurisdictions such as Singapore and Japan.