Transfer pricing professionals for financial services

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Partner: Toyoharu Nakamura

Partner: Toyoharu Nakamura

Toyoharu Nakamura began his career as a tax officer of the Tokyo Regional Taxation Bureau (“TRTB”) in 1973. In 1990, after having experienced numerous international examinations at the TRTB, Mr. Nakamura was appointed as Chief of the International Examination Section of the National Tax Agency (“NTA”). While primarily engaged in planning and directing examinations for multinationals conducted by the Regional Taxation Bureaus, Mr. Nakamura also acted as liaison between the NTA and foreign tax authorities in order to facilitate exchanges of information, cooperation in international examinations and competent authority negotiations. In 1992, Mr. Nakamura was appointed as Deputy Director, the Office of International Operations, the Commissioner’s Secretariat of the NTA. While primarily engaged in competent authority negotiations, he was also actively involved in OECD-CFA work programs, and made significant contributions to revision of the OECD Transfer Pricing Guidelines, and the issuance of the “Guidelines for Information Exchange between Competent Authorities”.  Mr. Nakamura joined Zeirishi-Hojin PricewaterhouseCoopers in September 2002, and has been providing transfer pricing consulting services to multinational corporations since.

Partner: Teruyuki Takahashi

Partner: Teruyuki Takahashi

Teruyuki Takahashi joined PricewaterhouseCoopers Singapore in October 1993. After entering Zeirishi-Hojin PricewaterhouseCoopers in May 2002, Mr. Takahashi has had extensive experience in advising on bilateral advance pricing arrangements (APAs) with various countries, such as U.S., Australia, Switzerland, Korea, Canada and China. In addition, Mr. Takahashi has been heavily involved in transfer pricing audits, planning projects and risk assessments for various industries, including financial services. Mr. Takahashi is a Singapore Certified Public Accountant.

Ryann Thomas

Partner: Ryann Thomas

Since she joined Zeirishi-Hojin PricewaterhouseCoopers in 2001, Ryann has worked exclusively in the transfer pricing area, assisting both inbound and outbound multinational corporations with transfer pricing audit defense, APAs and documentation for Global Trading (Spot Deals, Derivatives), Asset Management (Traditional, Alternative) and Investment Banking (Underwriting, M&A). Prior to coming to Japan, Ryann worked as a barrister and solicitor in commercial and private litigation in New Zealand. Ryann is currently Treasurer for the Australian & New Zealand Chamber of Commerce in Japan. Ryann is a graduate of the University of Auckland (majors in law and commerce) as well as Massey University (major in Japanese), and has been admitted to the bar of the High Court of New Zealand.

Naoki Hayakawa

Partner: Naoki Hayakawa

Mr. Hayakawa began transfer pricing with one of the Big Four accounting firms in 2003. Since that time, he has been involved in various transfer pricing-related advisory work, including documentation, planning, audit controversies, APAs, and advisory on competent authority matters for various outbound and inbound clients. Mr. Hayakawa was also seconded to New York during 2008 and 2009, during which time he focused on various financial services-related transfer pricing issues, both for U.S. and Japanese- based financial services clients. Mr. Hayakawa joined Zeirishi-Hojin PricewaterhouseCoopers in April, 2011. In that role, he will continue to focus on transfer pricing for financial services clients. Mr. Hayakawa has been a US Certified Public Accountant in the State of California since 2002.