Finance and Securities
Corporate and M&A
Major Projects
Tax
IP/IT/EC
Anti Trust
Our Tax Practice Group is one of the leading full-service, independent tax practices in Tokyo. The group provides comprehensive domestic and international tax planning, structuring, and controversy services in the following areas:

Inbound and outbound investments.
Mergers and acquisitions.
Transfer pricing planning and defense.
Income and withholding tax planning and structuring for the licensing of software and other intangible property.
Audit representation, administrative appeals, domestic litigation, and competent authority proceedings.
Real estate transactions.
Financial product related transactions.
Tax structuring of new business operations and joint ventures.
Expatriate individual tax matters.
Consumption tax (VAT) and other indirect taxes.
Customs.

The group includes specialists in both transfer pricing and corporate tax planning and structuring. In the area of transfer pricing, our lawyers have extensive experience in handling transfer pricing planning, audits and disputes involving Japan, the US and other countries relating to a broad range of industries. Our lawyers in the tax planning and structuring practice provide comprehensive advice on direct and indirect tax matters relevant to investments and business operations in Japan, including structuring advice for mergers and acquisitions, inbound and outbound investments, real estate transactions, and financial product transactions. The group also provides comprehensive representations in tax controversies including tax audits, domestic appeals and litigations, and competent authority proceedings.

The group's substantial experience in these areas, combined with its global resources and the diverse international training and background of its lawyers, make it a natural partner for domestic and international companies wishing to invest in Japan or expand their operations from Japan.
The group consists of 6 partners, 2 of counsel member, and 3 associates.

Two of the group's senior partners - Yukinori Watanabe and Kazuo Taguchi|joined the firm after distinguished careers at the highest levels of Japan's Finance Ministry and National Tax Administration respectively. Their experience extends and informs our understanding of how Japanese tax authorities handle real-world scenarios where clear laws and precedents are lacking, and allows us to advise our clients accordingly. A number of our lawyers, such as resident US tax partner Ed Whatley, are tax specialists both in their home jurisdictions as well as in Japan. This blend of domestic and international knowledge allows us to address a company's global tax posture when providing advice or services on a particular matter.

In addition, the group can tap into an extended network of more than 450 tax attorneys in 38 locations worldwide who comprise the Baker & McKenzie Global Tax Group as well as the broader organization of over 3,300 Baker & McKenzie attorneys who can lend their expertise in corporate, finance, securities, major projects, and intellectual property law to round out our services.
The following list highlights some of the group's recent client work in the areas of tax planning and structuring, and tax controversy:

Assisted a major domestic automobile company in gaining exemption from a government-mandated tax adjustment.
Handled Japan's first tri-lateral advanced pricing agreement involving the import and distribution of alcoholic beverages.
Advised a major domestic pharmaceutical company in its tax structuring, resulting in a 60 percent reduction of its overall tax liability.
Assisted a major domestic commercial bank with its successful \360 billion yen case against the Japanese government.
Helped a domestic group of banks win their case against a European government institution, and a domestic public organization win its litigation against the US government.
List of Partners
Kobayashi, Shinichi Taguchi, Kazuo Oka, Ryutaro
Ken, Okawara Watanabe, Yukinori Whatley, Edwin T.
Yamamoto, Hideyuki