Audited Japanese companies as tax inspector at the National Tax Administration Agency in relation to corporate income tax and consumption tax for 8 years and was involved in various international cases.
Advised a leading infrastructure company in Japan in its US$6 billion acquisition of a US multinational company.
Advised a Japanese leading electronics company in its business asset acquisition spreading over 44 countries that has spin off from a US multinational company.
Advised a Japanese food company in the Japanese CFC rule issue of its Ireland and Swiss-based captive re-insurance company, as well as its compliance with the relevant civil and company law requirements.
Advised an investment company of a Japanese conglomerate investing in Chile in its tax residency change from the Netherlands to Spain in relation to its dividend withholding tax problem in Chile, and assisted in obtaining advance rulings from Japanese, Dutch, Spanish and Chileans tax authorities, resulting in dozens of US million dollar annual dividend withholding tax savings.
Assisted a Japan-based multinational company in obtaining an advance clearance with Japanese tax authorities in relation to its Singapore subsidiary as to whether its intangible development is outside the scope of the Japanese CFC rule.
Advised an Ireland subsidiary of a Japanese multinational conglomerate in its global tax structuring of an aircraft leasing project.
Assisted a Japanese multinational conglomerate in obtaining an advance clearance with the Japanese tax authorities in relation to the deductibility of hundreds of millions of US dollar losses incurred by its Singaporean shipping subsidiary as a result of transferring its vessels to a Panama subsidiary followed by a retrenchment.
Assisted a Japan’s leading multinational company in setting up its first full scale tax policy controlling its global operation.
Acted as international tax advisor for several large scale Japanese multinational companies and was involved in the day-to-day international tax matters they were facing.
Acted as tax committee member for various government/business organisations and has been the Japanese representative for Business and Industry Advisory Committee (BIAC) to OECD, which handles Base Erosion and Profit Shifting (BEPS) problems, since 2009.
Tax Planning for Japanese Corporate Investors in Australia, with an Emphasis on Conceptual Difference in Income between Australia and Japan’, MBA Research Report, University of Queensland - 1994
‘How Multi-lateral Instruments Influence on Japanese Companies’, The 21 Century Public Policy Institute - 2018
‘Tax Management System for Japanese Multi-national Companies after BEPS’, The 21 Century Public Policy Institute - 2017
‘How to set up infrastructure for proper tax compliance in accordance with BEPS’, Ministry of Economy, Trade and Industry - 2015, co-author
‘Cross-Border M&A’, Hitotsubashi Business Review, Toyo Keizai Shimpo-Sha - 2013, co-author
‘How should Japanese companies deal with PE taxation?’, Japan Machinery Association - 2012, co-author
‘CFO Guidebook’, Tokyo Keizai Shimpo-Sha - 2012, co-author
Regularly works with...
InsightView all Firm insight
17 May 2019 - Video
Withers meets art
16 May 2019 - Article