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Partner
Admitted to bar |
1982, Japan |
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Languages |
Japanese and English |
Contact |
TEL : +81-3-6889-7121 |
Practice Areas |
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.
1980 | The University of Tokyo (LL.B.) |
1982- | Nagashima & Ohno (currently Nagashima Ohno & Tsunematsu) |
1987 | University of California, Los Angeles (LL.M.) |
1987-1988 | Paul, Hastings, Janofsky & Walker LLP, Los Angeles |
1988 | Covington & Burling LLP, Washington, D.C. |
1991-present | Partner, Nagashima & Ohno (currently Nagashima Ohno & Tsunematsu) |
April 2005-March 2007 | Visiting Professor (Tax and International Tax Law), Sophia University |
April 2007-March 2013 | Visiting Professor, Graduate School of International Corporate Strategy Hitotsubashi University |
April 2013-present | Visiting Professor (International Tax Law), The University of Tokyo School of Law |
October, 2015 | Articles | Getting the Deal Through - Transfer Pricing 2016 Japan (co-author) |
September, 2014 | Articles | Getting the Deal Through - Transfer Pricing 2015 Japan (co-author) |
January, 2004 | Articles | New US-Japan tax treaty offers investment boost The IFLR Guide to Japan 2004 (Supplement to International Financial Law Review, January 2004) |
January, 2001 | Articles | The International Guide to the Taxation of Transfers of Technology Japan International Bureau of Fiscal Documentation |
May, 1993 | Articles | Japan's Transfer Pricing Policies are Being More Rigorously Enforced International Taxation, May 1993 |
July, 1992 | Articles | 1992 Tax Law Amendments Affecting International Transactions CCH Journal of Asian Pacific Taxation, July/August 1992 |
July, 1991 | Articles | Japanese Transfer Pricing Regulations CCH Journal of Asian Pacific Taxation, July/August 1991 |
December 5, 2019 | Awards | |
September 25, 2019 | Awards | NO&T receives high evaluation in World Transfer Pricing 2020 |
September 25, 2019 | Awards | |
September 17, 2019 | Awards | NO&T receives high evaluation in Asialaw Profiles 2020 and Asialaw Leading Lawyers 2020 |
April 4, 2019 | Awards | High evaluation received in the 2020 Edition of "The Best Lawyers in Japan" |
January 17, 2019 | Awards | NO&T receives high evaluation in The Legal 500 Asia Pacific 2019 |
November 30, 2018 | Awards | |
August 17, 2018 | Awards | |
April 6, 2018 | Awards | High evaluation received in the 2019 Edition of "The Best Lawyers in Japan" |
December 11, 2017 | Awards |