International Taxation

Tax issues relating to international transactions are increasing due to the globalized economic activities of corporations, their overseas expansion, and an increase in business reorganizations. Tax authorities are expanding their audit capabilities for international transactions, and there is a growing trend for such authorities to upwardly revise their tax assessments for such transactions. These types of taxation risks are becoming a growing problem that corporations cannot ignore; accordingly, the need for expert legal advice is increasing.

Our firm handles domestic tax issues, and provides advice on all international taxation matters, including: transfer pricing rules, anti-tax haven rules (CFC rules), taxation of permanent establishments (PE), withholding tax, application of tax treaties, various transactions including cross-border transactions and foreign law-governed transactions, international taxation issues involving foreign entities, and international organizational restructuring for establishing regional controlling subsidiaries.

We also advise clients on, for example, the planning stages of M&A and other international transactions, and tax investigations focusing on potential legal disputes, as well as strategize and provide representation for tax disputes (e.g., request for reinvestigation, petition at the National Tax Tribunal, tax litigations), and prepare legal opinions for submission to tax authorities.

To provide the optimum tailored legal services for each of our client’s international taxation needs, our team is comprised of lawyers and licensed tax accountants with diverse backgrounds, experience, and qualifications.

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