Japan

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Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

Ken Okawara is the head of the transfer pricing and economic analysis group at Baker McKenzie. He specialises in managing Japanese transfer pricing issues and resolving transfer pricing disputes. He also assists clients with designing transfer pricing policy and international tax planning for companies. The team provides services including transfer pricing planning, documentation and defence, economic analysis of transfer pricing and valuation of intangibles and other assets. The transfer pricing group has extensive government experience and some of its professionals have crucial positions within Japan’s tax authority. In addition, the foreign lawyers at Baker McKenzie have both their home jurisdiction and Japanese work experience, which brings a broader tax posture to clients.

Deloitte Tohmatsu Tax

Michael Tabart is the head of the transfer pricing practice at Deloitte Tohmatsu Tax. The transfer pricing team has more than 130 professionals, including 13 partners working from Tokyo, Osaka and Nagoya. It provides transfer pricing services to the headquarters of outbound clients. Tetsuya Kawase is the head of transfer pricing practice in Nagoya and mainly helps clients in the automotive industry. Jun Sawada and Timothy O’Brien assist inbound clients. Hiroki Yamakawa and Akira Akamatsu deal with the complicated controversy cases. The transfer pricing team helps to meet the needs of Japanese and foreign multinational companies and also serves financial service industries.

In 2017, partner Kei Maeda advised one Japan-based chemical company on transfer pricing policy integration after M&A. The team provided services including establishing transfer pricing models consistent with BEPS Actions 8-10. It helped the client achieve the transfer pricing model on the complicated transactions. 

Kai Hielshcer, a PhD economist and transfer pricing partner, recently joined Deloitte Tomatsu Tax. Ken Takahashi joined the team in 2018 as the head of the transfer pricing for financial institutions.

DLA Piper

Makiko Kawamura is the head of the transfer pricing team at DLA Piper. The team specialises in the design, documentation and implementation of transfer pricing policies. It assists clients with the valuation of intangibles and other assets and dispute resolution. Dispute resolution involves audit defence, APAs, MAPs and a mediation practice. It also advises clients on transfer pricing litigation and witness support.

Makiko Kawamura represented one client on its US APA application deal. The team serviced the client by providing detailed economic analysis on its finance activities and giving supporting arguments on the issue.

Grant Thornton Taiyo

Grant Thornton has 15 partners and 110 professionals, organising under the Japan Licensed Tax Account Law. The firm’s services include transfer pricing documentation for global companies and the preparation of transfer pricing policies for Japan-based SMEs engaged in international transactions.

In 2018, Katsuhiko Asakura helped Topre prepare BEPS documentation, including Country-by-Country Report, master file and local file. Yoichi Ishizuka and Katsuhiko Asakura also assisted IDC with preparing transfer pricing policy for a company planning IPO.

KPMG Japan

The transfer pricing team has 12 partners in Tokyo, Osaka and Nagoya. The team provides services involving bilateral and unilateral APA negotiation, transfer pricing documentation, transfer pricing audit defence, MAP procedure, domestic appeal and litigation procedures and transfer pricing policy planning. They help both Japanese and foreign-based multinational firms in a wide range of industries, including manufacturing, pharmaceuticals, software, trading, finance and natural resources. The team assists clients with mitigating transfer pricing risks. It also formulates and maintains strategies for global tax planning while working closely with professionals in the corporate tax and customs or VAT groups. Nobuhiro Tsunoda, one of the experienced experts of KPMG, once served as a senior office of the National Tax Agency and has dealt with negotiations with the competent authorities of more than 20 countries on more than 300 cases. 

In 2017, Koichiro Fujimori, Mamiko Kimura and Ryosuke Watanabe advised one Japanese office equipment manufacturer on a commissionaire conversion project. The transfer pricing team designed new transactional flows and developed new pricing policies. The case was conducted across seven countries in Europe and Japan. In addition, the team took into account the culture habits of the client.

Nagashima Ohno & Tsunematsu

Yuko Miyazaki is the head of the transfer pricing team at Nagashima Ohno & Tsunematsu. Atsushi Fujieda and Yushi Hegawa are the leading partners. The team provide services including the preparation of transfer pricing documentation and audit defence. 

In 2017, Yushi Hegawa helped a premier French luxury gadget manufacturer in a matter concerning documentation work. It helped the Japanese subsidiary of the client to prepare transfer pricing documentation. It also involved careful drafting so that the Japanese tax authorities should not overrate the functions and risks of the Japanese subsidiary.

Tokyo Kyodo Accounting Office

Ryutaro Uchiyama is the head of transfer pricing practice at Tokyo Kyodo Accounting Office. The firm advises clients on transfer pricing risk assessment, transfer pricing documentation requirements, MAPs, APAs and the development of a global pricing policy. It also advises clients on the implementation of a corporate reorganisation plan by considering transfer pricing issues. 

In 2018, Shuji Fujita helped one client promote necessity of transfer pricing. The innovation is documentation toward Japanese SMEs at the request of the Japanese Ministry of Economy Trade and Industry.

The firm has expanded with the addition of manger Wataru Misonou, who was hired from the National Tax Authorities in 2017.