Our Tokyo tax group provides general tax services in collaboration with other groups and DLA Piper’s overseas offices, to companies operating internationally, and has considerable experience in the following areas:

International tax planning and advice

International tax planning is an essential and important element in conducting any business, management, transaction or investment and has a significant impact on business decision-
making. Depending on the planning, it is possible to achieve a significant improvement of the quality of tax [benefits] by minimizing the tax consequences of international operations.

Although international tax planning is highly complex, our Tokyo office has experience in transactions involving companies in a variety of countries and businesses and can provide effective tax planning, optimizing the network with our overseas offices familiar with local tax laws. Further, we are also able to point out problems that could arise in the course of global business operations and suggest solutions. In recent years, we have provided advice on many cases such as restructuring of international supply chains and custom valuation.

Handling of tax issues pertaining to cross border M&A and internal restructuring

It is necessary to develop an effective acquisition scheme for tax purposes for the success of cross border M&A and internal restructuring. Many transactions require attention to different regulations in foreign countries as well as taxation on stakeholders including shareholders and domestic tax law issues such as tax avoidance for developing an effective transaction scheme.

The Tokyo office can provide advice in collaboration with other service groups and DLA Piper’s overseas offices familiar with local tax laws so that any international merger may be carried out under an optimum scheme. We will also take care of taxation, integration procedure, notification to competent authorities and other post-closing related matters.

Handling of transfer pricing taxation

It is important for global companies to avoid tax risks by taking proactive measures against transfer pricing taxation that is subject to increasingly rigorous inspections by competent authorities of each country. Our Tokyo office can provide services in every aspect of both domestic and overseas planning with respect to the transfer pricing taxation, including proactive development of transfer pricing policies, review of transaction agreements and response to a transfer pricing inspection (including mutual consultations), if any.

We also provide global one-stop services with respect to consumption taxes, customs, tax inspections and tax disputes, international stock option planning and other related matters.