Tax Analysis and Structuring | Tax & Transfer Pricing | Legal Services

About

In addition to offering tailored advice with respect to local tax analysis in Japan, we conduct sophisticated international tax analysis, including tax optimization, for major corporations. Our partners (our licensed tax attorneys are called “tax partners”) are supported by a team of Japanese and foreign tax associates, and of counsel affiliates who are former senior tax officials able to consult with and assist in contacting the Japanese tax authorities.

The core of the Tax Analysis and Structuring practice is the international tax practice. This team advises multinational clients regarding a broad range of international tax issues in connection with activities in Japan, providing practical solutions to complex issues that may arise in the world’s number three economy. Our Tax Group’s litigation practice is also well versed in analysis of increasingly complicated tax issues not only from a tax perspective but also from law and financial perspectives, and thus supports our tax analysis and transfer pricing practices.

Our outbound tax practice is a subdivision of the Tax Analysis and Structuring practice and focuses on advising Japanese multinationals with regard to international tax issues in connection with outbound activities, making use of Baker McKenzie’s global network of tax professionals to provide practical advice from an international perspective. The final subdivision of our Tax Analysis and Structuring practice is our inbound/domestic tax practice. The team’s members, who are licensed tax attorneys in Japan, conduct inbound/domestic tax services for foreign multinationals and provide solutions to tax issues arising in connection with other corporate transactions in Japan.

Representative Experience

Assisted a US semiconductor manufacturer with a major restructuring project which included the transfer of intangibles from Japan to a more tax efficient jurisdiction and the subsequent conversion of the Japan operations to a contract manufacturer.
Assisted a US pharmaceutical company with the transfer of intangibles from Japan to a more tax efficient jurisdiction. Also advised on the creation of a Japanese NK for US tax purposes.
Regularly provided comprehensive analysis of Japanese operations to determine the most efficient corporate structures from both a tax and legal perspective. Our team has assisted where necessary with the restructuring of domestic and global operations as appropriate (commissionaire, etc.)