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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:
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Inbound and outbound investments. |
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Mergers and acquisitions. |
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Transfer pricing planning and defense. |
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Income and withholding tax planning
and structuring for the licensing of software and other intangible
property. |
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Audit representation, administrative
appeals, domestic litigation, and competent authority proceedings. |
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Real estate transactions. |
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Financial product related transactions. |
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Tax structuring of new business operations
and joint ventures. |
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Expatriate individual tax matters. |
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Consumption tax (VAT) and other indirect
taxes. |
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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. |
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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.
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The following list highlights
some of the group's recent client work in the areas of
tax planning and structuring, and tax controversy:
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Assisted a major domestic automobile
company in gaining exemption from a government-mandated tax
adjustment. |
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Handled Japan's first tri-lateral advanced
pricing agreement involving the import and distribution of alcoholic
beverages. |
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Advised a major domestic pharmaceutical
company in its tax structuring, resulting in a 60 percent reduction
of its overall tax liability. |
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Assisted a major domestic commercial
bank with its successful \360 billion yen case against the Japanese
government. |
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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. |
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