Naoki Hayakawa

Naoki Hayakawa

Partner, PwC Tax Japan

Transfer Pricing Services


After having worked for a Japanese bank, Mr. Hayakawa joined a transfer pricing group of one of the Big 4 accounting firms in 2003. Since then, he has been involved in various transfer pricing-related advisory work. Mr. Hayakawa specializes in transfer pricing, including documentation, planning, audit controversies, APAs, and advisory on competent authority matters for various outbound and inbound clients. During 2008 and 2009, he was on a secondment in New York and focused on transfer pricing matters. During the secondment, he focused on the financial services sector including global trading, banking and capital markets, traditional and alternative asset management, treasury, and insurance for US-based and Japanese financial services clients. Mr. Hayakawa joined the transfer pricing group of PwC Tax Japan in April, 2011. Mr. Hayakawa is a leading transfer pricing advisor for financial services sectors. He is also familiar with complex financial transaction transfer pricing issues.

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Project Results and Achievements

  • Global Transfer pricing policy establishment, documentation, audit support, APA and mutual agreement procedure support for Japanese multinationals and financial services companies
  • Transfer Pricing advisory to commercial banks, investment banks and leasing companies
  • Transfer Pricing advisory on post-merger integration
  • Support on branch/PE profit attribution for Financial services companies
  • TP advisory on Funds Transfer Pricing
  • Global documentation projects, head office expense allocations
  • TP policy establishments and documentation projects on intercompany loans, asset finance, acquisition finance, loan guarantee, performance guarantee, insurance, re-insurance, risk transfer, treasury dealings etc.

Professional Vision

As our clients’ business become complex, tax issues have become more complex than ever. Mr. Hayakawa wishes to be an advisor who can always bring new ideas and values to the clients.