Atsushi Fujieda

Biography

Atsushi Fujieda handles tax litigation and appeals cases, including transfer pricing disputes. He represented Takeda Pharmaceutical Company Limited in a certain transfer pricing dispute to successfully achieve cancellation of a correction in the amount of JPY 24.6 billion at the National Tax Tribunal in 2013, and represented Honda Motor Co., Ltd. in a transfer pricing litigation to successfully achieve the cancellation of a correction in the amount of JPY 25.4 billion based on the residual profit split method for the first time at the Tokyo District Court in 2014, which was further affirmed by the Tokyo High Court in 2015. He also represented Isuzu Motors Limited in tax litigation to successfully dispute the validity of certain local tax ordinance at the Supreme Court, resulting in a refund of approximately JPY 63.5 billion in total to not only Isuzu Motors but also many other corporate taxpayers of such local tax in 2013. This case was the second victory at the Supreme Court after a certain corporate income tax case representing NTT DoCoMo in 2008.