Tax: International firms and joint ventures in Japan

Baker McKenzie (Gaikokuho Joint Enterprise)

Baker McKenzie (Gaikokuho Joint Enterprise)'s tax and transfer pricing group provides a full range of domestic and international tax planning, structuring, and economics services to multinational clients and to Japanese businesses seeking tax advice in foreign jurisdictions. The firm fields lawyers, accountants, tax practitioners, and transfer pricing experts under the leadership of Edwin Whatley with the notable support of Shinichi Kobayashi and Ryutaro Ota.

Practice head(s):

Edwin Whatley

Other key lawyers:

Shinichi Kobayashi; Ryutaro Ota

DLA Piper

The tax group in DLA Piper operates as an integral part of the firm's broader Asia practice and services Fortune 500 companies in relation to international and domestic tax restructuring and supply chain remodeling, M&A transactions, as well as disputes relating to customs duties and consumption tax. Practice head Makiko Kawamura has a strong track record acting for multinational clients, including Kawasaki Heavy Industries and Yamaha Motors, with respect to transfer pricing and advanced pricing agreements.

Practice head(s):

Makiko Kawamura

Key clients

Avex Group Holdings Inc.

Gemological Institute of America Inc.

Fortive Corporation

Ralph Lauren Corporation

Work highlights

  • Appointed to advise on all tax issues arising from embassy operations and a related real estate project in Japan on behalf of a foreign government.
  • Representing a global conglomerate with regards to a complicated tax optimization plan including transfer of subsidiaries, consolidation election of the group, debt push down of the acquisition funds and to implement those plans.
  • Representing a Japanese listed manufacturing company in the renewal of its APA between Canada and Japan.
  • Representing a Japanese public company in starting up a US business and providing tax structuring advice in relation to restructuring of businesses globally.
  • Advising a leading global semiconductor manufacturer on their international tax restructuring.

Jones Day

Jones Day's Japan-based tax team works closely with the firm's M&A, intellectual property, real estate and finance practices as well as with its overseas offices, particularly in the US. Led by of counsel Koichi Inoue, the group primarily advises on outbound cross-border transactions, the restructuring of overseas operations conducted by Japanese companies, as well as inbound transactions conducted by foreign companies in Japan, and tax disputes.

Practice head(s):

Koichi Inoue

Testimonials

‘The main difference between Jones Day and the four major accounting firms is that clients can receive international tax advice from Jones Day’s team with a view to appealing national tax and litigation in the future. Also, unlike domestic law firms, the firm’s tax team can immediately obtain information about overseas tax regulations.’

‘Inoue Koichi has extensive experience in international tax litigation. He has the know-how to guide taxpayers to a win.’

Withers Japan, Zeirishi Houjin

Withers Japan, Zeirishi Houjin specialises in structuring foreign investment funds entering the Japanese market, specifically through a Singapore treaty platform. The team is led by Asian corporate tax head Eric Roose and consists of senior Japanese lawyers representing both domestic and international clients who need guidance with issues arising from foreign tax credits, withholding tax complications, and tax audits. Senior tax counsel Kenichi Takashima recently joined the practice from KPMG.

Practice head(s):

Eric Roose

Other key lawyers:

Takeo Mitzutani; Kenichi Takashima

Testimonials

‘The firm is very well positioned with investment fund clients and is known for providing proactive advice on all aspects of domestic and international tax laws.’

‘Withers is specialised in tax advice in the context of international real estate investments into Japan.’

‘The tax team is led by Eric Roose who is practical and responds swiftly.’

‘Eric Roose is a well-known international tax expert with more than 30 years of experience in Japan as well as the US and Singapore. He has built a strong tax offering in Tokyo by recruiting some of the best tax advisors in the country.’

‘Eric Roose is one of the first true international tax specialists working in Japan.’

‘Eric Roose is a pragmatic and knowledgeable tax practitioner who runs his tax team efficiently and effectively. It is through his leadership that the firm functions well as a tax adviser in Japan.’

Key clients

Pacific Alliance Group

Mapletree Investments Ltd Pte

Shenning Investments

State Street Capital

TH Real Estate

UBS AG

Credit Suisse

Bank of Singapore