The Tax Group’s litigation practice successfully resolves tax disputes with revenue authorities by employing a wide variety of administrative dispute resolution techniques. Our services span the research phase, requests for administrative review, litigation and mutual agreement procedures. Working together with other Tax Group members and members of the Tokyo Dispute Resolution Group the team led several of our clients to success in some of Japan’s most notable taxpayer victories. We regularly handle a wide range of major tax dispute cases, including trials and APA competent authority negotiations.

Representative Experience

  • Represented a Japanese electronic component manufacturer in a transfer pricing matter which resulted in the National Tax Tribunal’s (“NTT”) JPY14.1 billion reversal of a deemed revenue assessment. The NTT’s decision to reverse the assessment, released on February 1, 2010, resulted in the largest tax refund ever made in a transfer pricing matter in Japan at the time.
  • Represented an international software company in litigation seeking reversal of transfer pricing taxation of its subsidiary. In a landmark ruling in favor of the client on October 30, 2008, the Tokyo High Court for the first time reversed a transfer taxation assessment.
  • Represented a Japanese pharmaceutical company in a request for administrative review and litigation seeking a reversal of transfer pricing taxation.
  • Represented a Japanese glass manufacturer in filing a request for administrative review, seeking reversal of transfer pricing taxation.
  • Represented a US insurance company in tax litigation on derivative transactions which resulted in the reversal of a JPY11 billion tax assessment.
  • Represented a Japanese government organization in tax appeals and litigation relating to withholding tax in multiple jurisdictions.
  • Represented a US cosmetics company in its administrative appeal in relation to customs/consumption tax (VAT) adjustments.