Goro Mizushima

Goro Mizushima

Partner, PwC Tax Japan

International Tax Services


Goro Mizushima has more than 15 years of experience in the transfer pricing field, serving both Japanese and non-Japanese multinational clients in various industries. He also spent two years on assignment with the Transfer Pricing Group in the PwC Germany Dusseldorf office from 2018 to 2020.

Goro has been involved in projects including transfer pricing tax study, advance pricing agreements (APA), transfer pricing documentation (master files and local files), and transfer pricing risk assessment for a variety of industries including the automotive, industrial machinery, semiconductor, medical device, consumer goods, aviation, food and beverage, asset management and entertainment industries.

With respect to APA in particular, Goro has been engaged in a number of large projects involving the US, Canada, Mexico, Switzerland, Ireland, Germany, Singapore, Thailand and Korea.


  • Certified Public Tax Accountant


  • Speaker at various transfer pricing seminars and webinars at PwC Tax Japan and client companies
  • “Recent updates on transfer pricing issues in Germany and their measurements” (September 13, 2019 at Japanische Industrie- und Handelskammer zu Dusseldorf)
  • “Overview of Japanese transfer pricing legislation relating to the operations of German multinationals in Japan” (February 10, 2021 at the German Chamber of Commerce and Industry in Japan)
  • “Japan Transfer Pricing Update” (March 25, 2021 at CCI France Japon)


  • "Introduction to 'Transfer Pricing' for the practical use in business" (Co-authored. 2023, CHUOKEIZAI-SHA.)
  • “Procedure for relief from double taxation resulting from transfer pricing assessment” (PwC's View, February 2023)
  • “Procedure for relief from double taxation resulting from transfer pricing assessment” (Zeimu QA, December 2022)
  • “Transfer pricing tax audit environment (Trends in Germany)” (Kokusai Zeimu November 2020)
  • “FY2019 Japan Tax Reform: Implementation of Commensurate with Income Standard and DCF Method <3> - Case study from Germany” (Kokusai Zeimu January 2020, co-author)
  • “Transfer pricing risk management in China, Thailand and emerging countries” (Kokusai Zeimu April 2013, co-author)

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