At Baker McKenzie (Gaikokuho Joint Enterprise), the tax and transfer pricing group assists multinational clients with operations in Japan with advisory, transactional and contentious tax matters. The team is prominent in tech, media, telecom, life sciences, and financial services, and its broad offering covers international tax planning, transfer pricing planning, domestic litigation, administrative appeals, and tax structuring relating to mergers and acquisitions. Notable for his extensive experience in handling US and Japanese tax matters, Edwin Whatley oversees the practice. Cross-border M&A taxation and direct and indirect tax matters are the area of expertise of Ryutaro Oka and Shinichi Kobayashi. Hideyuki Yamamoto, who servers as chairman of the Tokyo Bar Association Tax Committee, is recommended for tax litigation. Yukiko Komori focuses on pricing agreements and tax planning. Other key names include Akihiko Tsuda and of counsel Luke Tanner.
Tax: International firms and joint ventures in Japan
Baker McKenzie (Gaikokuho Joint Enterprise)
Practice head(s):
Edwin Whatley
Other key lawyers:
Ryutaro Oka; Shinichi Kobayashi; Hideyuki Yamamoto; Yukiko Komori; Akihiko Tsuda; Luke Tanner
DLA Piper Tokyo Partnership Gaikokuho Kyodojigyo Horitsu Jimusho
The tax department at DLA Piper Tokyo Partnership Gaikokuho Kyodojigyo Horitsu Jimusho is active across a number of industries, spanning tech, insurance, healthcare, infrastructure, and retail, where it acts for domestic, regional and Fortune 500 companies. The group is geared to handle international and domestic tax restructurings, supply chain remodelling, customs duties disputes, and the tax aspects of mergers and acquisitions. California and New York-qualified Lance Miller is a key contact for cross-border tax matters relating to venture capital and M&A transactions. Miller leads the group alongside of counsel Keitaro Uzawa, who focuses on international and domestic taxation, transfer pricing and disputes before the National Tax Agency and the Customs.
Practice head(s):
Lance Miller; Keitaro Uzawa
Key clients
Foot Locker
Work highlights
- Advised Foot Locker on its Japanese tax issues together with M&A legal advice by corporate team in connection with their acquisition of atmos, a digitally led, premium, global footwear retailer headquartered in Japan.
Jones Day
Jones Day boasts a longstanding presence in the Japanese market, where it often advises both domestic and international companies on the tax aspects of cross-border transactions, including M&A, corporate restructurings, audits and transfer pricing, with a emphasis on outbound matters. Koichi Inoue heads up the team and is especially sought after to handle complex administrative proceedings as well as high-stakes tax litigation and audits. Inoue works alongside Taku Osawa, who focuses on tax disputes and transfer pricing matters, and Kyosuke Katahira, whose expertise spans M&A, joint ventures and licensing agreements.
Practice head(s):
Koichi Inoue
Other key lawyers:
Kyosuke Katahira; Taku Osawa
Withers Japan, Zeirishi Houjin
At Withers Japan, Zeirishi Houjin, the international corporate tax team sits within the firm’s international commercial practice, which regularly collaborates with its offices in the UK, US, Singapore, Kong Hong and Australia, to handle cross-border tax matters for multinational companies, private equity firms and high-net-worth individuals. Leading the team is Eric Roose, who is specialised in inbound and outbound investments and global tax treaties. Other key names include international tax adviser and licensed tax attorney Kohei Kobayashi, who joined the firm in September 2021 from PwC Legal Japan, and associate Erin Gutierrez, who often assists high-net-worth families with inheritance tax and estate planning matters.
Practice head(s):
Eric Roose
Other key lawyers:
Kohei Kobayashi; Erin Gutierrez
Key clients
MPower Partners Fund LP
FLOW Digital Infrastructure
PAG Real Estate Property Fund III
Nuveen Alternative Living Fund
Work highlights
- Assisted MPower Partners Fund LP with the launch of its Japan’s first environment, social and governance (ESG) focused global venture capital fund.
- Advised FLOW Digital on its overall tax structure, whose objective is to become the largest data centre business in the Asia Pacific Region.
- Acted as lead tax counsel for Pacific Alliance Group’s $2.8bn APAC real estate fund, which will invest in commercial, logistics, infrastructure, residential and retail property in the APAC region.
PwC Legal Japan
Led by Michito Kitamura, PwC Legal Japan‘s tax practice offers corporates strategic advice on tax structuring and audits, litigation and administrative proceedings. Kitamura, who has extensive experience in handling the tax aspects of M&A, restructuring and ESG-linked transactions, is often sought after to represent clients in disputes involving foreign entities classification and deb-equity swap tax treatment. He is supported by director Kozo Kuromatsu, who is well versed in tax audits, litigation and transactional matters.
Practice head(s):
Michito Kitamura
Other key lawyers:
Kozo Kuromatsu