International Taxation
Providing advice on international taxation issues relating to various transactions including cross-border transactions
Tax issues relating to international transactions are increasing due to the globalized economic activities of corporations, their overseas expansion, and an increase in business reorganizations. Tax authorities are expanding their audit capabilities for international transactions, and there is a growing trend for such authorities to upwardly revise their tax assessments for such transactions. These types of taxation risks are becoming a growing problem that corporations cannot ignore; accordingly, the need for expert legal advice is increasing.
Our firm handles domestic tax issues, and provides advice on all international taxation matters, including: transfer pricing rules, anti-tax haven rules (CFC rules), taxation of permanent establishments (PE), withholding tax, application of tax treaties, various transactions including cross-border transactions and foreign law-governed transactions, international taxation issues involving foreign entities, and international organizational restructuring for establishing regional controlling subsidiaries.
We also advise clients on, for example, the planning stages of M&A and other international transactions, and tax investigations focusing on potential legal disputes, as well as strategize and provide representation for tax disputes (e.g., request for reinvestigation, petition at the National Tax Tribunal, tax litigations), and prepare legal opinions for submission to tax authorities.
To provide the optimum tailored legal services for each of our client’s international taxation needs, our team is comprised of lawyers and licensed tax accountants with diverse backgrounds, experience, and qualifications.
Recent Work
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- 2024.1
- Mitsubishi Estate Co., Ltd.’s Investment in CapitaLand’s business park in Chennai, India
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- 2021
- Shionogi & Co., Ltd. - Rescission of tax reassessments (Tokyo High Court)
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- 2020
- Shionogi & Co., Ltd. - Rescission of tax reassessment
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- 2019
- Arbitration involving significant claims and its settlement concerning a joint venture between Japanese companies relating to power plant construction projects
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- 2019
- Takeda Pharmaceutical Co., Ltd. - Acquisition of Shire plc
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- 2005 - 2007
- Tax Litigation concerning Repurchase Transaction (Supreme Court, Tokyo High Court, Tokyo District Court)
Awards & Rankings
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Nishimura & Asahi carefully considers the legal arguments - they're capable of constructing persuasive arguments in the application of complex tax provisions. "high expertise, flexibility and strong engagement."
Chambers, Tax (Asia-Pacific 2022)
Seminars
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N&A Legal Forum
Legal and tax seminar on M&A investments into the Netherlands
Sunrise Hall, Otemon Tower 10th Floor, Nishimura & Asahi
Nishimura & Asahi Seminars
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Country Risk and Its Countermeasures for Foreign Investment in the Future
Online
External Seminars
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Foreign Investment and Country Risk in Light of COVID - 19
Online
External Seminars
Publications
News
- Media
- Takato Masuda’s comments were quoted in an article entitled “Japanese Financial Services Agency Proposes Amending Foreign Tax Credit Rules in Response to Russia's Suspension of Tax Treaties,” which appeared in IBFD Tax News Service
- Media
- Takato Masuda’s comments were quoted in an article entitled “Japan Proposes Pillar 2 Amendments in Tax Reform Bill,” which appeared in Tax Notes International
- Media
- Takato Masuda’s comments were quoted in an article entitled “Japan Levies Tax and Penalties of JPY 3.5 Billion on Cross-Border Digital Content of Popular Online Game,” which appeared in IBFD Tax News Service