Michael Polashek

Michael Polashek

Partner, PwC Tax Japan

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.

Contact Form

Contact details


Project Results and Achievements

  • Assisted major U.S. consumer products MNC in planning and implementing major business restructuring, including assistance with APA application covering restructuring transaction and post-restructuring transfer pricing, wherein very favourable APA terms were achieved.
  • Advised major U.S. multinational on migration of manufacturing and product IP of acquired Japanese developer/manufacturer to U.S. entity and on post-migration transfer pricing for licensee/distributor and contract manufacturer in Japan.
  • Assisted major U.S. IT MNC in 2 year transfer pricing / permanent establishment tax audit that resulted in no assessment.
  • Assisted major U.S. medical device MNC in 2 year transfer pricing audit that resulted in no assessment.

Other Activities

  • Frequent speaker at transfer pricing seminars and conferences.

Professional Vision

To understand clients and help them define and achieve their objectives.