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Home > Lawyers > Partners > Atsushi Fujieda

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Partner

Atsushi Fujieda

Atsushi Fujieda

Admitted to bar

1982, Japan

Languages

Japanese and English

Contact

Contact this Lawyer

TEL : +81-3-6889-7121
FAX : +81-3-6889-8121

Practice Areas

General Corporate, Tax Advice and Planning, Tax Disputes

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.

Education/Professional Experience

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

Publications

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

Topics

December 5, 2019

Awards

NO&T recognized by Chambers Asia-Pacific 2020

September 25, 2019

Awards

NO&T receives high evaluation in World Transfer Pricing 2020

September 25, 2019

Awards

NO&T receives high evaluation in World Tax 2020

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

NO&T recognized by Chambers Asia-Pacific 2019

August 17, 2018

Awards

NO&T lawyers recognized in Tax Controversy Leaders 2018

April 6, 2018

Awards

High evaluation received in the 2019 Edition of "The Best Lawyers in Japan"

December 11, 2017

Awards

NO&T recognized by Chambers Asia-Pacific 2018