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Home > Practices > Tax > Tax Disputes

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Tax Disputes

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. We are actively engaged in numerous tax dispute cases at every stage of the dispute, including tax audits, administrative appeals, and court proceedings. The greatest strengths and hallmarks of our firm's tax practice are our ability to successfully resolve disputes at the audit stage without any assessment being issued, and our ability to achieve optimum results for our clients in administrative appeals and litigation by representing and advocating for their best interests.

We have a strong performance record in litigious tax matters, having obtained excellent results in many high-profile tax litigation cases such as:
• the Kanagawa Prefecture Temporary Special Enterprise Tax case;
• the NTT DoCoMo case;
• a case relating to a disallowance of capital losses arising from a share buy-back transaction by invoking the general anti-avoidance statute;
• a case relating to the application of a tax treaty to tokumei kumiai profit distributions;
• a case relating to the valuation of an insurance policy for inheritance tax purposes;
• a case relating to the valuation of stock of a holding company for inheritance tax purposes;
• a case relating to the tax classification of foreign business organizations (limited partnerships);
• a case relating to an exemption of deficiency penalty tax;
• a case relating to retirement without disposal of thermal electric power plants;
• a case relating to cross-border 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.

In addition, in the area of transfer pricing, through administrative appeal procedures, we have secured complete cancellations of enormous transfer pricing assessments levied upon a Japanese pharmaceutical company, as well as a successful resolution of transfer pricing audits for a Japanese electrical products company and a Japanese automobile parts manufacturer, each resulting in no amount of tax being assessed. Through mutual agreement procedures, we have also been successful in securing cancellation of transfer pricing assessments levied upon various parts manufacturers. Further, we have acted for various taxpayers, such as manufacturers of automobiles and electric parts, sea carriers and apparels companies in large-scale transfer pricing dispute cases.
In addition, we have been involved in large-scale tax disputes in an area in which there are few precedents, such as those involving reorganization transactions, anti-tax haven regimes and so-called general anti-avoidance statutes.

Further, we contribute to the optimal resolution of tax disputes outside Japan that Japanese companies face, particularly in emerging countries in Asia and Africa, through strategic planning and the supervision of local advisors.


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