PwC Financial Services

In order to compete in the global financial market, not only is knowledge of the Japanese taxation system imperative, but knowledge of the overseas tax regimes in the financial industry is also required. In order to advise on complicated financial products traded in the financial markets, tax advisors who have specialized focus, expertise and training in financial services are imperative for successful tax planning. There is also an increased need for tax experts in the real estate market and finance market particularly in the structuring of these business lines and analyzing the tax risks associated with such structures.

PricewaterhouseCoopers (PwC) has over 80 professional staff specializing in taxation in the financial services industry who provides high-quality domestic and overseas consulting services with the cooperation of overseas PwC offices and our Assurance and Advisory practices in Japan.

• Consulting services inherent to tax issues of financial institutions
• • Transfer Pricing
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    Transfer pricing issues relating to global trading and cost sharing arrangements within groups of financial institutions have been of great interest to Japan’s National Tax Agency recently. In order to plan and advise on transfer pricing considerations unique to financial institutions, PwC’s financial transfer pricing team provides highly technical professional services by adopting an updated analytical approach.
    
    
  • Corporate Reorganisations
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    As a result of the recent tax reform on corporate reorganizations, financial institutions have adopted diversified approaches to their corporate reorganizations. In particular, when a corporate reorganization takes place on a worldwide basis, careful consideration should be given not only to the domestic tax treatment but also to the overseas tax consequences of the reorganization. PwC provides integrated global tax reorganization advice for such restructurings.
    
    
  • Insurance Companies
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    Insurance companies have unique tax issues pertaining to the accounting treatment of reserves and insurance products. We have formed a specialized insurance consulting team to specifically advise on these tax issues and to provide consulting services regarding the reorganization and M&A transactions of insurance companies. This often requires close cooperation with our Assurance and Advisory practices.
    
    
• Tax compliance services for financial institutions
• We provide tax compliance services for domestic and overseas financial institutions including the preparation of tax returns and tax reports and application forms for treaty withholding tax rates.
• Consulting advice for various financial products
• Due to our extensive financial services expertise and experience, we provide advice relevant to investment trusts, derivative products, structured bonds, and assets denominated in foreign currencies. We also provide advice on the most tax efficient solutions for highly technical financial restructuring that have inherently complicated tax considerations such as asset liquidation schemes and international lease transactions.
• Consulting advice for real estate investment schemes
• The Japanese tax regime concerning the liquidation and securitization of real estate has been developed to accommodate the environmental changes of the domestic economy. PwC has a specialised real estate and fund tax department, comprised of both Japanese and foreign professionals who are dedicated specifically to Japanese real estate tax optimization and are the leading market participants in establishing and assisting tax efficient real estate structures.
  
  PwC has a track record in providing a broad range of services required by our clients for investing in Japanese real estate, including coordinating and undertaking due diligence, analyzing structuring documentation, structuring service and asset management agreements and structuring financing, joint venture and securitization agreements, the establishment of Tokumei Kumiai and SPCs.
  
  In line with development of J-REIT as a new financial product, we are the tax advisors for many of the J-REITs currently on the market. Based on that experience, we have the expertise to advise on all aspects of J-REITs including common business practice.
• Consulting advice for business recovery funds by financial institutions
• Recently, corporate acquisitions and business recoveries by foreign-affiliated funds are actively being conducted in Japan. Corporate recovery funds for the rehabilitation of domestic companies’ businesses by Japanese financial institutions are also becoming common.
  
  Since the tax treatment largely depends on the recovery method elected by companies, careful tax planning in order to reduce tax costs for creditors, debtors and sponsors is an important factor for the success of the business recovery plan.
  
  We provide consulting services to both domestic and foreign-affiliated financial institutions advising on the most suitable business recovery method including corporate spin-offs, establishment of funds, and due diligence, in order to achieve increased tax efficiency.