Transfer Pricing Support for Inbound Companies

Foreign-headquartered multinational enterprises doing business in Japan are faced with an additional burden in managing their Japanese transfer pricing as compared with their Japanese-headquartered peers. Not only must foreign tax management deal with technical transfer pricing issues that are common to other jurisdictions, they must also deal with the cultural aspects of a foreign country that manifest themselves in the Japanese tax authorities’ rules, practices and procedures.

Zeirishi-Hojin PricewaterhouseCoopers’ Transfer Pricing Consulting Group employs transfer pricing specialists from a variety of countries besides Japan. Many of our inbound transfer pricing specialists have been practicing transfer pricing in Japan for many years, and are very familiar with the ins and outs of Japanese transfer pricing practice at the grass roots level. This makes us uniquely qualified to help foreign-headquartered MNEs with their Japanese transfer pricing issues. Not only are we able to advise on the technical transfer pricing aspects, we can also help to navigate the unfamiliar cultural and procedural waters. We accomplish this with a team of transfer pricing professionals with strong qualifications and varied backgrounds:

  • Native English speakers at all professional levels, including 2 Partners and 1 Managing Director, who have been practicing transfer pricing in Japan for several years and are long term residents of Japan
  • Native Japanese speakers with fluent English capability at all professional levels, many of whom have been educated or have worked overseas
  • Native Japanese and English speakers with direct experience of transfer pricing practice in other countries, such as the US, UK and Asia, through PwC’s active global secondment program
  • Dedicated transfer pricing translators, fluent in both Japanese and English

This broad range of capabilities allows us to provide a depth of services that distinguishes us from our competitors.

We are happy to bring all of our experience and capability, including our in-depth understanding of the Japanese transfer pricing environment, to bear on behalf of foreign-headquartered clients, whether already operating in Japan or considering entering the Japanese market in the future.