The role of tax lawyers in the context of tax disputes is becoming increasingly important, due to the current vigorous enforcement policy of the Japanese tax authority. Nagashima Ohno & Tsunematsu is actively engaged in numerous tax controversy cases at every stage of dispute, including tax audits, administrative appeals, and court proceedings. The greatest strength, and hallmark, of our firm's tax practice is our ability to successfully resolve disputes at the audit stage without any assessment being issued, and also our ability to achieve optimum results for our clients in administrative appeals and litigation by representing and advocating for their best interests.

Nagashima Ohno & Tsunematsu has a strong performance record in litigious tax matters, having obtained excellent results in many high-profile tax litigation cases such as:

• the NTT DoCoMo case;
• a case relating to retirement without disposal of thermal electric power plants;
• a case relating to cross-boarder repo transactions conducted by a financial institution; and
• a case relating to collection gains from loan receivables acquired in connection with the acquisition of bank assets.

Also, in the area of transfer pricing, we have secured successful resolution of transfer pricing audits for Japanese electrical products companies, resulting in no amount of tax being assessed, and have acted for various taxpayers such as automobile manufactures and pharmaceutical/healthcare companies in large-scale transfer pricing controversy cases.