Transfer Pricing Services
U.S. attorney, U.S. CPA
15 years’ experience in the international tax area, including the last 14 years with PwC Tax Japan.
- Assist foreign MNCs with all facets of transfer pricing practice in Japan, including advance pricing agreement (APA) applications, audit defence, mutual agreement procedures (MAP), transfer pricing aspects of business restructurings, documentation and other transfer pricing related matters.
- Have worked with clients in a variety of industries, with particular emphasis in medical device, pharmaceutical, consumer products, high-tech and electronics industries.
- Have helped clients with successful conclusion of over 20 Japan APAs, mainly bilateral APAs with various treaty partners, sometimes involving complex restructurings and/or difficult negotiations.
- Have helped numerous clients achieve successful resolution of transfer pricing tax audits.
- Intimately familiar with Japan practice and procedure as it pertains to APA applications and transfer pricing audits, with deep experience in developing appropriate strategies to achieve the best possible outcomes.