Japan has seen economic growth over the past year as a result of private consumption and strong international trade in Asia, a trend which looks set to continue. Despite this, it is not all rosy for Japan, as the country's aging population and rapidly decreasing workforce mean Japan has to find ways of boosting growth. Deflation also continues to be a problem for the Asian country.
However, Japan has plans for expanding the economy. In March 2017, Japan enacted a tax reform bill, which introduced many changes relevant to multinational corporations. The measures included in the bill are intended to support investments and the local economy, limit tax avoidance and amend measures in line with the BEPS recommendations.
Among other things, Japan is introducing spin-off taxation, amending controlled foreign corporation and anti-tax haven rules, revising research and development tax credit computation and amending the tax treatment of tax directors' compensation.
In November 2016, Japan decided to postpone its planned consumption tax rate increase, which will now be effective from October 2019. Some believe this was an unwise move as Japan has one of the highest public debts among developed countries, and a consumption tax would spread the tax burden across all consumers and reduce public debt. However, the country hopes to strengthen its economy and promote growth with its broader tax reform plans.
Ernst & Young Tax Co.
Kasumigaseki Building 32F
Tel: +81 3 3506 2411
Area/Country Tax Leader
Tel: +81 3 3506 2411 (Tokyo) / +81 6 6315 1298 (Osaka)
Law Leader, EY Law Co. – Member of Dai-Ichi Tokyo Bar Association
Tel: + 81 3 3509 1668
Business Tax Services *co-leader
Tel: +81 3 3506 2843
Tel: +81 3 3506 2463
Global Compliance and Reporting *co-leader
Tel: +81 3 3506 2843
Tel: +81 3 3506 2463
Tel: +81 3 3506 2678
International Tax Services
Tel: +81 3 3506 2426
Tel: +81 3 3506 2430
Tel: +81 3 3506 2637
Grant Thornton Taiyo Tax Corporation
Grant Thornton Taiyo Tax Corporation is a leading and experienced tax firm, providing dynamic organization with high quality taxation services.
Aoyama Bldg. 12F, 1-2-3 Kitaaoyama, Minato-ku
Tokyo 107-0061 Japan
Yoichi Ishizuka (CEO)
1-1-2 Otemachi, Chiyoda-ku
Offices in Japan:
Tokyo, Nagoya, Osaka, Fukuoka
Bangkok, Beijing, Shanghai, Dubai, Hanoi, Hoh Chi Minh City, Jakarta1, Singapore, Yangon, Hong Kong2
1Associate Office 2Affiliate Office
Yo Ota <firstname.lastname@example.org>
Akihiro Hironaka <email@example.com>
Nishimura & Asahi ("N&A"), which has approximately 500 Japanese lawyers (bengoshi), 50 foreign lawyers, tax counsel (zeirishi) and other professionals, is the largest law firm in Japan, and its practice areas cover all aspects of international and domestic business and corporate activities. N&A is particularly renowned for its expertise in dealing with various types of tax controversies, exemplified by its unparalleled track record of victories before the Japanese courts. Further, N&A develops and implements creative tax solutions and strategies for M&A transactions, group restructuring, financing arrangements, the development of financial products, and other complex transactions. N&A understands its clients' growing needs, and its fully integrated team of lawyers and professional staff are proud to share the same fundamental philosophy: An uncompromising commitment to excellence.
Since its founding in 1993, Tokyo Kyodo Accounting Office (TKAO) has provided top class accounting and taxation services. Marshalling its highly trained cadre of certified public accountants, licensed tax attorneys, consultants and experts from other fields, TKAO provides services exquisitely tailored to the specific needs of its corporate and individual clients.
TKAO's professional service offerings include International Taxation / Transfer Pricing, Corporate Finance, Private Banking / Financial Planning, Structured Finance, SPC Management and Other Services.
International Taxation / Transfer Pricing / FTAs
TKAO provides a wide range of accounting and tax consulting services with regard to international trades and cross-border investments, i.e. transfer pricing, FTAs, inbound and outbound international tax planning.
TKAO provides a wide range of services relating to key strategic transactions, from financial advisory and tax planning in connection with restructurings, stock purchases, business transfers, mergers, capital increases through third party allotments, formation of business alliances and initial public offerings, to post merger integration services.
Private Banking / Financial Planning
TKAO provides complete and comprehensive services that cover the entire wealth formation and succession cycle, e.g. advisory services for initial public offerings of shares or other ways of monetizing privately owned businesses; consulting services for financial asset investment, e.g. units in investment trusts, real estates and insurances or inheritance and business succession planning services.
TKAO is regarded as the premier accounting office in Japan's securitization industry with roles in numerous key projects, covering securitization as well as investment fund transactions for various asset classes, including receivables, real estate and intellectual property.
As a SPC pioneer in Japan, TKAO provides a broad range of services covering the entire SPC life cycle – from advisory services for transaction structuring, and SPC incorporation, administration and management of SPCs during the on-going phase, to liquidation services.
|Corporate Income Tax||23.9%||A|
|Capital Gains Tax||23.9%||A|
|Net Operating Losses (years)|
|Royalties from, for example, patents, know-how||20%||C|
|Branch Remittance Tax||0%||N/A|
A) Local income taxes are also imposed. The resulting effective corporate income tax rate is approximately 33% (35% for corporations with stated capital of JPY100 million or less).
B) Except for the withholding taxes on royalties and certain interest, these withholding taxes are imposed on both residents and non-residents. For non-residents, these are final taxes, unless the income is effectively connected with a permanent establishment in Japan. Royalties paid to residents are not subject to withholding tax.
C) Under the special law to secure funds for reconstruction related to the March 11 2011 disasters, a special additional income tax (2.1% of the normal withholding tax due) is imposed for a 25-year period running from January 1 2013 through December 31 2037. As a result, the 20% withholding tax rate is increased to 20.42%, and the 15% rate is increased to 15.315%. However, this special additional income tax does not affect reduced withholding taxes under existing income tax treaties.
D) Interest paid to residents on bonds, debentures or bank deposits is subject to a 20% withholding tax, which consists of a national tax of 15% and a local tax of 5%. Other interest paid to residents is not subject to a withholding tax. Interest paid to non-residents on bonds, debentures or bank deposits is subject to a 15% withholding tax. Interest paid to nonresidents on national and local government bonds under the Book-Entry Transfer System is exempt from withholding tax if certain requirements are met.
E) The loss carryback is temporarily suspended.
F) The carryforward period of losses arising in fiscal years beginning on or after April 1 2017 will be extended to 10 years.
Edwin Whatley is the head of the tax practice at Baker McKenzie. The practice comprises six partners and 13 other fee earners. The practice provides tax advice to MNEs operating in Japan and to Japanese clients engaged in business in foreign jurisdictions. The tax services Baker McKenzie offers these clients include tax planning and structuring for M&A, indirect tax, real-estate transactions and representing clients in audits, administrative appeals and domestic litigation.
In 2016, the practice advised an American real estate investment trust in a corporate tax matter. This matter concerned the client's acquisition of a data centre operator in Japan. Baker McKenzie ensured that the transaction complied with the requirements of a US real estate investment trust.
The practice is representing an American healthcare equipment and services company in a tax dispute regarding whether a reduced holding tax rate is applicable under a tax treaty. The practice is representing the client before Luxemburg and Japan competent authorities. Baker McKenzie is also advising a Japanese subsidiary of a US technology company in an indirect tax matter. This is in relation to the Japanese consumption tax which includes a new cross-border services regime.
The tax practice at Deloitte Tohmatsu Tax has 64 partners and 704 other fee earners. Shinya Matsumiya is the head of the tax practice. Since May 2016, Ichiro Hirayama, Hirokazu Yoshida, Yukiko Okuno and Tetsuo Iimura have joined the practice.
The practice provides a range of tax services, including international tax, indirect tax, tax dispute resolution, M&A and global business tax.
Deloitte Tohmatsu Tax has offices in 16 cities across Japan including Osaka and Nagoya. This enables the practice to work closely with its clients. The practice provides tax advice for Japanese and foreign MNEs. The practice has collaborated with DT Legal Japan since 2015, a Japanese professional law corporation which specialises in corporate tax matters, M&A, tax controversy and labour and employment.
The practice works with the Japanese Services Group. This enables the practice to access a network of more than 1,000 Japanese bilingual professionals operating in more than 80 cities. The practice is able to provide the appropriate advice to Japanese companies carrying out their business in foreign jurisdictions.
Makiko Kawamura is the head of the tax practice at DLA Piper. The practice comprises one partner and four other fee earners. Hidehiro Go joined the practice in January 2017. The practice provides clients with advice on tax matters including consumption taxes, customs duties, tax investigations and tax controversies. Its clients include Japanese and international MNEs that work in Japan and abroad.
DLA Piper is advising a Japanese pop music business operator on the restructuring of the client's foreign subsidiaries in Asia and the US. This is in order to minimise tax risks and burdens. The practice is also representing a client in a dispute with the tax authority over a tax assessment. The tax authority imposed a withholding tax on the client regarding the sale of stock options in a mergers and acquisitions transactions. The practice is challenging the authority's decision.
The tax practice at Ernst & Young Tax Co has 36 partners and 555 other fee earners. The practice members include economists and professionals who have previously worked with the tax authorities. Kenji Amino is the head of the tax practice. Since May 2016, Kazumi Hirai, Nobuo Mori, Naoko Kito, Shusaku Nishikawa, Takashi Iizuka, Emiko Okubo and Yoshiaki Uno have joined the practice.
The practice offers its clients services in indirect tax, corporate tax, tax disputes and tax compliance. The clients of the practice include MNEs based in Japan and in other jurisdictions. The firm assists clients with complying with cross-border reporting obligations, recommending structuring alternatives, locating advantages in the market and handling international tax risks. The practice can rely on EY's international tax network and its global tax desk program. This enables the practice to effectively advise its clients and help them achieve its objectives.
The firm has a strong relationship with Japan's Ministry of Economy, Trade and Industry (METI), which regularly obtains the opinions of the tax professionals at the practice regarding tax legislation. EY also provides tax seminars for MNEs.
Grant Thornton Taiyo Tax Corporation's tax practice provides clients with a wide range of tax services including tax compliance, international tax, litigation and inter-company transaction planning. The practice's headquarters is in Tokyo and it has another office in Osaka. As a part of Grant Thornton International, the practice has access to a global network of more than 42,000 Grant Thornton professionals across more than 130 countries.
Yoichi Ishizuka is the firm's chief executive officer and managing partner. Ishizuka is supported by Yoichiro Sato and Hiroyuki Hamamura. Both Sato and Hamamura are managing partners. The firm's other partners are Takayuki Yumoto, Eiji Miura, Hideharu Tanaka, Yoshikatsu Suzuki, Arihiro Hino and Setsuko Tashiro.
The professionals at Jones Day's tax practice include Koichi Inoue, Taku Osawa and Kyosuke Katahira. Inoue has more than 30 years of tax experience which includes international transactions, investments and dispute resolutions. His clients include MNEs and he provides them with tax advice in relation to transactions across multiple jurisdictions. He also advises them on the restricting of their international business activities. Inoue has worked with clients from a variety of industries including pharmaceuticals, telecommunications and private equities.
Osawa is counsel at the practice and his legal tax experience includes international corporate law, M&A and real estate. He previously worked for the Osaka Regional Taxation Bureau as an audit officer. Katahira is an associate at the practice. He provides tax advice to foreign-based companies regarding domestic tax, restructuring and tax treaties. Katahira also acts as counsel for the practice on tax issues.
Eiki Kawakami is the head of the tax practice at Kojima Law Offices, Taxand Japan. In the practice there are four partners and 11 other fee earners. The practice members consist of lawyers and certified tax accountants. The tax services that the practice offers include international tax, litigation, transaction tax, compensation, real estate and corporate tax compliance. Kawakami has 30 years of experience in assisting clients with domestic and international tax matters. His expertise includes tax litigation.
In 2016, Kawakami advised a Swedish company that established an entity in Japan. He provided the client with tax planning and tax compliance services through all stages of the entity's creation. In the same year, the practice handled VAT matters including tax advice in relation to a popular UK musician's Japanese tour performance. The practice's advice concerning Japan's VAT legislation helped its client avoid incurring taxes that did not apply to the client.
Yuichi Komakine is the head of the tax practice at KPMG. The practice comprises 48 partners and 550 other fee earners, and has offices in Tokyo, Osaka and Nagoya. It provides tax advice in relation to financial services, M&A and real estate investment. The practice's clients include inbound and outbound MNEs from a range of industries including real estate, financial services and life sciences.
The practice has a team that provides trade and customs services as well as VAT services. KPMG is strong in the real estate area and assists a variety of investors in complex investments and has also been involved in many real estate transactions.
KPMG members are part of international organisations and business societies in Japan. Kenichi Takashima is a member of the Business and Industry Advisory Committee to the OECD. Takashima is also a member of the International Tax System Study Group in the 21st Century Public Policy Institute. Nobuhiro Tsunoda is an observer on two committees: the Committee on Fiscal Affairs at the OECD, and the United Nations' Committee of Experts in International Cooperation on Tax Matters.
Atsushi Oishi is the head of the tax practice at Mori Hamada & Matsumoto. There are nine partners and eight other fee earners at the practice. Hirotaka Murakami joined the practice in March 2017.
The practice provides its corporate and individual clients with tax planning services. It is particularly strong in advising clients in M&A, corporate reorganisations and cross-border transactions. Mori Hamada & Matsumoto also has a wealth management practice that provides high-net-worth individuals with estate planning and related services.
The firm is experienced in handling tax disputes between the taxpayers and tax authorities. The practice advises clients at the tax investigation stage, enabling the development of the strategies that prepare the taxpayers for potential tax disputes.
In 2016, the practice advised UACJ Corporation, a Japanese aluminium manufacturer, on the acquisition of SRS Industries LLC, a US manufacturer of automotive aluminium structural materials. Oishi and Makoto Sakai assisted the client with due diligence, structuring and documentation.
Yuko Miyazaki is the head of the tax practice group at Nagashima Ohno & Tsunematsu. The practice comprises four partners and eight other fee earners. These fee earners are made up of five associates, two senior counsel and one adviser.
The practice provides clients with tax advice and tax planning in regards to their business transactions, including M&A and reorganisation transactions. The practice also handles tax litigation matters that have garnered media interest. Mamoru Toba is a full-time special counsel. Toba previously worked at the Tokyo Regional Taxation Bureau as commissioner. He maintains a good working relationship with the tax authorities and gets their views on tax issues. Miyazaki has more than 30 years of experience advising MNEs on tax matters. Her experience includes international taxation and providing tax advice regarding financial or securities transactions. In 2016, she represented Japan-based entities owned by a US-based investment fund group in a tax dispute. The practice secured a Supreme Court decision setting aside a withholding tax assessment.
The tax practice at Nishimura & Asahi comprises lawyers and tax accountants. The practice advises clients on international taxation matters. These matters include restructuring, M&A and tax investigations.
Other services that the practice offers its clients include tax planning and tax counselling. Nishimura & Ashi assists its clients with tax disputes with the tax authorities, and the practice submits legal opinions in objection proceedings to reverse decisions taken by tax authorities. The firm's tax accountants and lawyers work together to try and obtain a favourable outcome for its clients.
Yasutaka Nishikori is a partner and one of his areas of specialisation is international taxation. His experience includes advising clients on international financial transactions. Nishikori helps the practice's clients with tax issues concerning structuring transactions. He also assists in tax disputes. In 2013, Nishikori was a member of the Japanese government's Expert Committee on Anti-Tax Haven Legislation and Intangible Assets. He has published several legal articles and is a lecturer.
Kazuya Miyakawa is the chief executive officer of the tax practice at PwC. The practice advises its clients on a range of tax matters including corporate tax, international tax, indirect tax, M&A, real estate and financial services. The practice is part of PwC's global network of firms. This network comprises more than 223,000 people in 157 countries.
The practice has several partners with many years of experience in tax matters. Hideo Kubota has been with the practice for 29 years. He advises Japanese and South Korean companies on tax compliance matters. Jun Takashima has more than 20 years of tax experience working with the practice. Takashima advises Japanese and foreign MNEs on corporate reorganisations, M&A and cross-border transactions. His expertise also includes acquisition structuring and post-acquisition integration. Hiroshi Takagi is the head of PwC's financial services and real estate tax teams. He advises his clients, often financial institutions, real-estate companies and investment funds, on cross-border structuring and financing matters. Akemi Kito has more than 20 years of experience as a tax adviser. Kito's clients include Japanese, US and European financial institutions. Kito advises them on matters including cross-border financing and investment structures. She also advises government agencies.
The tax practice at Tokyo Kyodo Accounting Office (TKAO) comprises seven partners and 24 other fee earners. The tax practice leader is Ryutaro Uchiyama. TKAO offers its clients advice on international taxation, covering outbound investment by Japanese companies and inbound investments in Japan by foreign companies. Other tax services provided by the practice include assistance with estate planning transactions, indirect tax planning and tax compliance, advice on project financing transactions, and corporate reorganisation.
The practice has also participated in a number of government projects which promote the greater utilisation of free trade agreements (FTA). For instance, the practice answered more than 5,000 questions from corporations in Japan concerning the use of FTAs and Economic Partnership Agreements. In 2017, the firm provided tax advice to a venture capital fund on obtaining 100% ownership of a non-profit organisation by its directors and employees.
The tax practice at Withers Japan, Zeirishi Houjin has four partners. The practice works closely with the firm's five regional offices in the Asia-Pacific, located in Tokyo, Hong Kong, Singapore, Sydney and Melbourne. The practice provides tax advice to clients in multi-jurisdictional projects. This tax advice includes M&A, foreign investments and corporate tax disputes.
Eric Roose is the head of the tax practice. Roose is also the leader of the firm's international corporate tax practice in Asia. Shingo Iizuka joined the practice in April 2017. Iizuka provides tax advice to foreign nationals and high-net-worth individuals. Chizuko Tomita advises clients on cross-border M&A issues, corporate tax restructuring projects and audits. Takeo Mizutani assists domestic and international companies on tax matters concerning their business activities in Japan. Mizutani also advises clients on foreign tax credits, withholding tax issues and tax audits.
In 2016, Roose, Tomita and Mizutani advised Time-Warner concerning the restructuring of the television rights for the client's assets.
|Tier 1- Japan|
|Deloitte Tohmatsu Tax|
|Ernst & Young Tax Co|
|PwC Tax Japan|
|Tier 2- Japan|
|Mori Hamada & Matsumoto|
|Nagashima Ohno & Tsunematsu|
|Nishimura & Asahi|
|Withers Japan, Zeirishi Houjin|
|Tier 3- Japan|
|Tokyo Kyodo Accounting Office|
|Tier 4- Japan|
|Kojima Law, Taxand Japan|