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Ken is a recognized expert in transfer pricing matters and economics. He has assisted many multinational companies in negotiations with tax authorities in Japan and several other countries. He has helped clients to resolve transfer pricing disputes at bilateral and multilateral competent authority proceedings. He has been involved in more than 50 APA / CA cases covering Japan, the US, the UK, Switzerland, Germany, Australia, Singapore, Malaysia, Korea and China. Ken also has significant experience in designing global transfer pricing policy and international tax planning for a variety of companies.
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Prior to joining Baker & McKenzie/Tokyo Aoyama Aoki Koma Law Office (Gaikokuho Joint Enterprise) in 2007, Ken held the following positions:
- Senior Partner and Head of Transfer Pricing Practice, Shin Nihon Ernst & Young, Tokyo (2002-2007)
- Lecturer, International Tax and Economic Policy, Gakushuin University, Tokyo (1999-present)
- Research Affiliate, Center on Japanese Economy and Business, Columbia University School of Business, New York (1997-present)
- Partner and Head of Transfer Pricing Practice, Arthur Andersen, Tokyo and Washington DC (1995-2002)
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Ken is a regular contributor to various tax and business journals and has published several books. He is also frequently invited to speak in Japan and overseas on transfer pricing and international tax issues. Below is a sample of Kenfs recent publications and presentations:
Books
- Transfer Pricing in Japan, (co-author, CCH Japan Limited., August 2010)
- 2008, Guide to Practical International Tax Planning, Chuokeizai-sha, Tokyo
- 2007, Effective Approach to International Tax Planning, Chuo Keizai Sha, Tokyo
- 2006, Transfer Pricing in Japan, CCH Asia Pte Ltd, Singapore
- 2005, Contemporary Transfer Pricing Issues and Some Proposed Solutions, Chuo Kouron Sha, Tokyo
- 2003 (with annual updates), eJapanf, in Tax Treatment of Transfer Pricing, IBFD, Amsterdam
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Articles
- “Developments in Japan”, “Transfer pricing disputes in Japan” BNA International, Transfer Pricing International Journal (March 2010)
- gTax Planning Strategy in Economic Downturn and Possible Repatriation under the New Dividend Tax Exemption Rules – Use of the Dutch Cooperativeh International Tax (April 2009)
- gImplications of Business Restructuring and Supply Chain Management to International Taxationh International Tax (October 2008)
- gTransfer Pricing Documentation: 2008, Japan, Tax Planning International Special Reporth BNA International (July 2008)
- gJapan Renews Scrutiny of Intangibles, Services BNA International (June 2008)
- gAsian update: China-Japan-Singapore – Transfer Pricing Development in Japan h BNA International Tax Planning International Transfer Pricing (June 2008)
- "Japan Transfer Pricing Documentation Guide" International Tax Review TP Week (January 2008)
- gTax Competition has Emerged in Countries all Around the World,h Weekly Economist (November 2006)
- gTax Agency Shows Way Forward on Taxing IP Transactions,h International Tax Review, Tax Reference Library No. 32 (December 2006)
- gHow Regulations and Administration in Japan Have Changed,h International Tax Review, Tax Reference Library No. 30 (Fall 2006)
- gExamining Effective Supply Chain Management in Europe,h International Tax (May 2006)
- gJapanese Taxation of Cross-Border Intellectual Property Transactions,h International Tax Review, Tax Reference Library No. 24 (December 2005)
- gTax Effective Construction Supply Chain Management Method,h Shuukan Touyou Keizai, (November 2005)
- gJapanese Transfer Pricing Regulations and Administration,h International Tax Review, Tax Reference Library No. 25 (Fall 2005)
- gAmendments to the Transfer Pricing Rulings: Business Problems and Proposed Solutions,h Junkan Keiri Jouhou (October 2005)
- gExamination of Problems in Transfer Pricing Methodologies Used for International Taxation,h Japan Academy of International Business Studies (September 2005)
- gTax Strategies on Enterprise Value Enhancement,h Shuukan Touyou Keizai (June 2005)
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Presentations
- The Netherland as investment hub seminar g The Netherland as European head-office locationh, Netherlands Foreign Investment Agency (NFIA), Tokyo (February 18, 2009)
- Business Research Institute Seminar gLatest International Tax Issues and measures for Global Business Managementh (November, 2008)
- 2008 Tax Executives International (TEI) Conference in California gCurrent Transfer Pricing Environment in Japanh (October, 2008)
- International Tax Review (ITR) Global Forum in Rome (September 2008)
- gThe Transfer Pricing System in Russia and Enterprise Response,h Japan Institute for Overseas Investment, Tokyo (June 12, 2007)
- gThe Importance of International Tax Cost and Risk Management and How do Deal with Them,h CFO Forum, Tokyo (December 9, 2005)
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| Ken has been a Licensed Tax Attorney (zeirishi) since 2005. Ken is a member of the Tokyo Licensed Tax Attorneysf Association, the International Fiscal Association, the Japan Tax Litigation Association, the Japan Tax Accounting Association, the American Economics Association, the American Business Economist Association and the Japan International Business Association. |
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Ken received a bachelor of economics from Gakushuin University in 1984, a master of economics from Gakushuin University Graduate School of Economics in 1986, a master of international affairs from Columbia University Graduate School of International & Public Affairs in 1988 and a Ph.D. from Chiba University School of Commerce in 2005.
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*@"Partner" as referred to in this material represents a senior-level professional who would be responsible for case management in each practice area, and does not mean profit-sharing members of the partnership. |
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