Tax: Independent local firms in Japan

Anderson Mori & Tomotsune

Anderson Mori & Tomotsune’s tax offering spans the spectrum of taxation matters including those relating to inbound and outbound transactions, corporate reorganisations and private equity/financing. Alongside corporate tax matters, the firm also offers individual, international, and public tax matters. The firm also has experience in audit representations, administrative appeals, litigation and negotiations with tax authorities. Koji Fujita and Eiichiro Nakatani  co-lead the team, both of whom advise on domestic and cross-border transactions. Akira Tanaka is also a name of note for tax planning and litigation.

Other key lawyers:

Akira Tanaka

Key clients

Universal Music LLC

Mori Hamada & Matsumoto

The tax team at Mori Hamada & Matsumoto focuses primarily on disputes and tax planning for both corporate and individual clients. The practice offers strength in M&A and corporate reorganisations both in domestic and cross-border transactions. On the individual taxation side of the practice the firm has extensive experience with high- and ultra-high net-worth individuals related to estate planning and other tangential services. The team is co-led by a trio; the newly promoted partner Hiroyuki Kurihara alongside Atsushi Oishi and Makoto Sakai. Oishi and Sakai handle a wide variety of tax-related transactional matters and investigations in the wealth management and M&A spheres. Another name of note is Hiroshi Oyama (recently promoted to partner) who also advises on tax planning and disputes.

Other key lawyers:

Hiroshi Oyama

Testimonials

‘I work with Mori Hamada regularly on a wide variety of M&A matters. They are highly knowledgeable and also commercial in their approach.’

‘Hiroyuki Kurihara is an excellent partner in the MHM tax team. He is responsive and practical, and also on the forefront of market developments such as SPACs.’

Key clients

Ministry of Finance

Hitachi, Ltd.

Crocs, Inc.

UACJ Corporation

Softbank Group Corp.

Randstad Holding nv

Sumitomo Electric Industries, Ltd.

GCA Savvian Corporation

Astellas Pharma Inc.

Baring Private Equity Asia

Johnson & Johnson

Shiseido Company, Limited

J-STAR Co., Ltd.

Appier Group, Inc.

Work highlights

  • Advised A.D.Works corporation on a JPY 1 billion (equivalent to USD 9.4 million) consumption tax lawsuit, in which the Tokyo District Court overturned a precedent decision and rendered its own decision in favour of the client.
  • Advised on the strategic alliance between Volvo Group and Isuzu Motors. Advised Volvo Group on the tax aspects of the sale of the worldwide operations of UD Trucks Corporation (Volvo Group’s wholly owned Japanese subsidiary) to Isuzu Motors for JPY 243 billion (equivalent to USD 2.92 billion).
  • Advised Appier Group, Inc. on the intra-group restructuring transactions, including a “qualified stock distribution” under Japanese tax law, for its listing on the Tokyo Stock Exchange, with a deal value of over JPY 140 billion (equivalent to USD 1.3 billion).

Nagashima Ohno & Tsunematsu

Nagashima Ohno & Tsunematsu’s tax team enters a new era following the promotion of Yushi Hegawa  to head of the tax practice group. Well known for its high-profile tax litigation practice, the firm acts for an impressive roster of domestic and international clients in addition to non-contentious tax advisory services. Hegawa routinely advises on multi-jurisdictional corporate and commercial transactions, audits, and disputes, cancellations, and nullification orders. Also notable are Koichiro Yoshimura and Tsutomu Endo who focus on corporate transactions and M&A.

Practice head(s):

Yushi Hegawa

Testimonials

‘Mr. Yushi Hegawa has already got good credit in the market, which we re-confirmed in the recent engagement. At the same time, we encountered Mr. Koichiro Yoshimura. He mainly prepared the rebuttal letter. This was impressive. Very intelligent, fair and clear arguments. Yoshimura sensei is equally splendid to Hegawa sensei. NO&T provided a perfect service in the recent engagement. Big thanks again I would like to make to both.’

‘Tax lawyers are much better at tax opinion/rebuttal letter than accounting firms especially when a tax-payer submits those letters against the Japanese Tax Authorities/various challenges. Depending on nature of our internal difficulties, we rely on tax-lawyers’ services accordingly.’

Key clients

Johnson Controls

Vivendi

UBS Securities

Mitsubishi Corporation

Veoneer Inc.

NGK Insulators

Work highlights

  • Represented Universal Music, LLC, a Japanese subsidiary of Vivendi, in a tax litigation requesting cancellation of a tax assessment, We are representing the client at the appellate level in furtherance of the Tokyo District Court decision, where we secured a court decision in favor of our client.
  • Represented Kokusai Kogyo Kanri Co. Ltd. before the Supreme Court in a tax litigation, where we secured a court decision in favor of our client, the petitioner, in which a corporate tax cabinet order was nullified.
  • Represented NGK Insulators before the Tokyo District Court in tax litigation requesting cancellation of a tax adjustment.

Nishimura & Asahi

Renowned for its handling of contentious tax issues, Nishimura & Asahi’s tax team maintains an excellent track record of Japanese court victories. Headed by Yo Ota, the team also advises on tax assessment reversals and audits. In addition, the firm also offers bespoke tax solutions and strategies for corporate restructurings and M&A, financing arrangements and financial product development. Ota has extensive experience in international and domestic M&A and cross-border transactions, particularly in the IP and media arenas. The team is also home to Akihiro Hironaka, who’s practice focuses on tax disputes and litigation, often with cross-border complications. Other key practitioners include Yasutaka Nishikori and Tsuyoshi Ito; their practices focus on financial instruments, tax planning, and transactions.

Practice head(s):

Yo Ota

Key clients

Shionogi & Co., Ltd.

Sumitomo Mitsui Trust Bank, Ltd.

Rakuten, Inc.

Work highlights

  • Represented Shionogi & Co. in a tax dispute before the Tokyo District Court, involving an issue arising from the in-kind contribution of a partnership interest for development of a drug to fight AIDS.
  • Represented Sumitomo Mitsui Trust Bank in a tax dispute involving withholding tax obligations due on interest paid to non-resident bondholders in the Tokyo District Court seeking cancellation of tax assessments by the Japanese tax authority.
  • Advised KKR and Rakuten with respect to the overall deal structure, drafting various agreements and assisting with the negotiations with the relevant parties, and also supported the smooth completion of the various acquisitions.

TMI Associates

With an established track record in funds-related tax matters, TMI Associates’ tax team has a strong cross-border and international practice. The team is headed by Hidehiro Utsumi, who combines both tax and corporate expertise to offer comprehensive advice to clients in litigation, audits, and transactional matters. Also of note is Nobukai Iwashina who co-leads the team and handles the gamut of domestic and international tax matters.

Key clients

Sompo Japan Nipponkoa Asset Management

Minimini Co., Ltd.

TOYO CORPORATION

Work highlights

  • Representing a wealthy individual, who owns a lot of real estate in a tax lawsuit in relation to inheritance tax.
  • Advised Aioi Nissay Dowa Insurance Co., Ltd. on CFC tax issues and pass-through nature of the investment funds the client has invested in.

Atsumi & Sakai

Atsumi & Sakai’s tax team offers expertise on contentious and non-contentious issues, including disputes, compliance, and cross-border matters. The team is led by Teruhisa Tomoya who has experience in litigation, risk management, due diligence, and M&A within a tax context.

Practice head(s):

Teruhisa Toyama

Yokogi & Masui Partners

New to the rankings, Yokogi & Masui Partners ’ tax offering is most known for its import transaction expertise. The firm’s service includes tax audits, consumption tax, and customs duties in the food, engineering and e-commerce industries. The team led by founding partner Yoichi Masui , an import transaction expert.

Practice head(s):

Yoichi Masui