Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

Edwin Whatley leads transfer pricing practice at Baker McKenzie. Other key practitioners include Hideyuki Yamamoto and Yukiko Komori. The team provides services including transfer pricing planning, documentation and defence, economic analysis of transfer pricing and valuation of intangibles and other assets. It has extensive government experience and some of its professionals have held crucial positions within Japan’s tax authority. In addition, the foreign lawyers have both their home jurisdiction and Japanese work experience, which brings a broader tax posture to clients. 

Deloitte Tohmatsu Tax

Kei Maeda leads transfer pricing practice at Deloitte Tohmatsu Tax. It has more than 150 professionals, including 17 partners and senior advisers working from Tokyo, Osaka and Nagoya. Partner Yusuke Nagano is the leader of transfer pricing practice in Osaka. Tetsuya Kawase is the head of transfer pricing in Nagoya and mainly helps clients in the automotive industry. Jun Sawada and Timothy O’Brien assist inbound clients. Hiroki Yamakawa and Akira Akamatsu deal with the complicated controversy cases. Masaki Yamada and Ken Takahashi focus on the transfer pricing for financial institutions. The team helps to meet the needs of Japanese and foreign multinational companies, especially those in the financial services sector. 

In 2018, the team helped a Japanese chemical firm valuing intangibles from a transfer pricing point of view. It also assisted a Japanese consumer products company with the implementation of its global transfer pricing policy. 

Howard Osawa joined the firm as a partner and Hiroshi Maruyama joined the firm as a director in 2019. 

DLA Piper

Makiko Kawamura is the head of the transfer pricing team at DLA Piper. The team focuses on the design, documentation and implementation of transfer pricing policies. It helps clients on the valuation of intangibles and other assets and dispute resolution. Dispute resolution involves audit defence, APAs, MAPs and a mediation practice. It also advises clients on transfer pricing litigation and witness support. 

Kentaro Ishida joined the firm as a tax advisor in 2018. 

Grant Thornton Taiyo

Managing partner Yoichi Ishizuka leads the transfer pricing practice at Grant Thornton Taiyo. Other key professionals include Harumi Yamada and Katsuhiko Asakura. It provides transfer pricing documentation practices including CbCR, master file and local file. The team helps mid-size firms that are in the IPO process with the implementation of policies. In addition, it also is engaged in post-tax-audit dispute procedures or competent authority procedures. 

In 2018, the team has expanded by hiring Takehiko Hara and Harumi Yamada. 

KPMG Japan

Nobuhiro Tsunoda is the key professional for transfer pricing practice at KPMG Japan. The team has 13 partners in Tokyo, Osaka, Nagoya and Hiroshima. It covers a wide range of services such as bilateral and unilateral APA negotiation, transfer pricing documentation including BEPS purpose and domestic appeal and litigation procedures. It helps both Japanese and foreign-based multinational firms in a wide range of industries, including manufacturing, pharmaceuticals, software, trading, finance and natural resources. 

The team helped a Japanese auto manufacturer by designing each transactional flow for the entire supply chain and developing pricing policies. 

Shuhei Ohshima joined the firm as a partner in 2018. 

Nagashima Ohno & Tsunematsu

Atsushi Fujieda and Yushi Hegawa lead transfer pricing practice at firm. Other key practitioners include Shigeki Minami and Takashi Saida. The team provides services including transfer pricing documentation, litigation and audit defence. 

The firm helped a luxury brand on a transfer pricing audit issue. It successfully represented the client during a transfer pricing audit by the tax authority. 

Nishimura & Asahi

The team at Nishimura & Asahi specialises in transfer pricing litigation issues. Key practitioners are Yo Ota and Tsuyoshi Ito. 

It is advising a Japanese manufacturer related to both transfer pricing and tax controversy issues. It includes legal analysis and strategy and preparing briefs to be filed with the tax tribunal. 

Tokyo Kyodo Accounting Office

Ryutaro Uchiyama leads transfer pricing practice at Tokyo Kyodo Accounting Office. It advises clients on transfer pricing risk assessment, documentation requirements, MAPs and APAs. It provides services regarding the development of a global pricing policy. The team also helps clients on the implementation of a corporate reorganisation plan by considering transfer pricing issues.