Baker McKenzie provides a wide range of transfer pricing / economic analysis services in relation to transfer pricing research, documentation, mutual agreement procedures, advance pricing agreements (APAs), litigation, company valuation, intangible asset valuation, and transfer pricing strategy building. Also, as a law firm, we provide comprehensive one-stop services, including strategic documentation, research and transfer pricing planning which takes potential litigation, reorganization, acquisition valuation, and intellectual property into account.

Baker McKenzie creates small teams of highly skilled professionals, allocating the minimum number of people necessary to a project to ensure that all team members, including the leading partner, pull their weight and enable the project to proceed effectively and successfully. The Tokyo office also has very close relationships with other offices across Baker McKenzie’s global network. Thus, the members of our international teams know each other very well and are well positioned to advise multinationals and provide them with truly the best solutions. We advise a number of corporations, many of them American companies, on the adoption of cutting edge tax strategies while also regularly advising on very conservative cases. Leveraging our treasure trove of experience to meet various client needs enables us to provide solutions and strategies that clients can’t come up with by themselves.

Representative Experience

  • Advised a US financial management company client in relation to US–Japan competent authority issues and transfer pricing adjustments.
  • Represented a Japanese pharmaceutical company in relation to a transfer pricing challenge of a royalty paid by the client’s Irish manufacturing subsidiary. The initial adjustment against the taxpayer was the largest NTA adjustment against a Japanese taxpayer to date, and ended in competent authority action.
  • Advised a Swiss pharmaceutical company regarding pricing issues relating to sales by the client of active ingredients to its Japanese subsidiary. The client was subject to two audit cycles, each ending in competent authority proceedings, in addition to APA negotiations.
  • Represented a US software company in its domestic appeal and litigation on a transfer pricing adjustment.
  • Advised Japanese motor vehicle manufacturers in relation to numerous US–Japan transfer pricing matters. Provided legal advice regarding audits, competent authority proceedings and US Tax Court litigation.