Japan

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 has a correspondent firm status with RSM International. The tax team offers services including indirect tax, M&A, business restructuring wealth management and transfer pricing. It has strengths in various sectors such as banks, security firms and investment funds. Kazuhiko Suda and Hiroshi Maruyama are the key partners in the team. Kazuhiko specialises in business restructuring and Hiroshi focuses on transfer pricing. 

A recent example of the firm’s work includes acting as a tax advisor to a licensed trust company. The work included providing international tax advice in respect of investment structure for offshore investors using a specified beneficial interest security-issuing trust. 

Harumi Sano joined the team as manager during the research period, while Kenichi Ono left the firm. 

Client feedback 

“They are well experienced and well informed in EPA related areas. They have already worked on EPA matters for quite some time. They work towards any issues very much proactively and with meaningful suggestions most of the time.”