Japan

Deloitte Japan

Shin Tokyo Building

3-3-1 Marunouchi

Chiyoda-ku Tokyo

Tokyo, 1008305

Japan

Tel: + 81 3 6213 3938

Fax: +81 50 3116 0190

Email: masahiko.kobayashi@tohmatsu.co.jp

Masahiko Kobayashi is a certified tax accountant and has been a partner of the transfer pricing consulting group of Deloitte Tohmatsu Tax (Deloitte Japan) since July 2008. He also has been a leader of Deloitte Japan's tax dispute resolution group.

Before joining Deloitte in 2006, he spent 26 years as a tax official in various departments of Japan's National Tax Agency (NTA), including the Tokyo Regional Taxation Bureau (TRTB), the National Tax College and local tax offices, as well as three years at the Ministry of Finance. In particular, he spent more than five years as a deputy director in the NTA's Office of Mutual Agreement Procedures (OMAP).

Through these roles, Masahiko gained significant experience in international tax, transfer pricing and APA's. While in the OMAP, he dealt with a wide variety of cases between Japan and various foreign competent authorities. These included major European countries and some Asian developing countries. Most of the double taxation cases he participated in managed to reach agreement among the parties involved. Since joining Deloitte, he has dealt extensively with transfer pricing disputes, including a case where a substantial amount of money was recovered for a foreign financial company through a tribunal procedure.

Other notable cases include: transfer pricing taxation and APA cases within the pharmaceutical industry; transfer pricing taxation and APA cases on global trading of financial derivative products; and PE taxation cases of foreign companies doing business in Japan, and those of Japanese companies doing business in foreign developing countries.

Masahiko is the co-author of 'All About Tax Audit in Japan' (Seibunsha 2013) and 'Transfer Pricing and Tax Management' (Seibunsha 2011). He is a member of the Japan Association of Tax Litigators and the Japan Tax Accounting Association.

PwC

Kasumigaseki Bldg 15F

2-5 Kasumigaseki 3-chome

Chiyoda-ku, Tokyo 100-6015

Japan

Tel: + 81 3 5251 2552

Email: daisuke.miyajima@jp.pwc.com

Website: pwc.com/taxcontroversy

Daisuke Miyajima is a partner in the international tax services (transfer pricing) group of PwC Tax Japan. During his more than 20 year career at the firm, he spent several years on assignment with the transfer pricing group in the Washington DC and New York offices. In the transfer pricing area, Daisuke has provided advice towards numerous Japanese and foreign clients on their inter-company transactions with related parties and the related effect on Japanese and foreign transfer pricing rules. He has also assisted in preparing studies for presentation to the appropriate tax authorities and has successfully defended several well-known Japanese and foreign companies in transfer pricing audits. He is also an expert in the area of competent authority negotiations and advance pricing agreements. While his experience includes clients in virtually every industry, he particularly specialises in the high-tech, automotive, entertainment, and luxury goods industries. Daisuke has also written extensively on the above areas in various publications and is a frequent speaker at seminars held by PricewaterhouseCoopers and outside organisations. He was chosen as one of the world's leading transfer pricing consultants by various publications. He also writes and is fluent in both Japanese and English.

Daisuke is also an associated member of the American Institute of Certified Public Accountants.

PwC

Kasumigaseki Bldg 15F

2-5 Kasumigaseki 3-chome

Chiyoda-ku, Tokyo 100-6015

Japan

Tel: +81 3 5251 2337

Email: akio.miyamoto@jp.pwc.com

Website: pwc.com/taxcontroversy

Akio Miyamoto is a partner in the international tax services (transfer pricing) group of PwC Tax Japan. He is a leading transfer pricing specialist in Japan with more than 20 years' experience in the field, beginning in 1991, which was around the time Japan commenced transfer pricing examinations, after the introduction of transfer pricing legislation in 1986. Given Japan's robust transfer pricing audit environment, and the wide use of advance pricing agreements (APAs) in Japan, he has been extensively involved in transfer pricing audit defence cases, competent authority negotiations, APA negotiations, transfer pricing documentation projects and transfer pricing risk assessment reviews. As one of the first transfer pricing professionals in Japan, Akio has an in-depth knowledge of Japanese transfer pricing practice and procedures.

He has assisted foreign and Japanese multinational clients in numerous industries, with particular emphasis in the medical device, pharmaceutical and luxury goods industries, which he has been involved with since the time the Japanese tax authority began to focus on these industries. He also has significant experience in the consumer goods and technology industries. He has dealt with a wide variety of transfer pricing and transfer pricing related issues, including business restructurings, profit attribution to permanent establishments, treaty application to transfer pricing disputes and commissionaire structures. He has also participated as a speaker at various transfer pricing conferences throughout the world.

Akio joined the Tokyo office of Price Waterhouse in 1979 and spent four years working in Price Waterhouse's Toronto office. His career began in audit, and he was heavily involved with both Japanese and non-Japanese multinationals. He moved to transfer pricing in 1991, and has been leading the Japan firm's transfer pricing practice since then. Miyamoto has been a partner since 1995.

Miyamoto is a licenced Japanese certified public accountant (CPA) and a licenced Japanese certified public tax consultant. He holds a bachelor's degree in commerce from Waseda University.

Deloitte Japan

Shin Tokyo Building

3-3-1 Marunouchi

Chiyoda-ku Tokyo

Tokyo, 1008305

Japan

Tel: +81 3 6213 3927

Fax: +81 50 3033 0434

Email: jun.sawada@tohmatsu.co.jp

Jun is a partner of Deloitte Tohmatsu Tax Co. (Deloitte Japan), working in the transfer pricing group. After starting his career with Arthur Andersen in 1999, Jun has advised both foreign and Japanese multinationals on various transfer pricing and cross-border taxation issues. Before joining Deloitte Japan in October 2013, Jun worked with EY and White & Case.

Jun has represented clients in various discussions with the Japanese tax authorities. He has defended companies under audit, assisted companies in their negotiations with tax authorities to obtain advanced approval of their transfer pricing (through unilateral/bilateral APAs), and supported companies in domestic tax appeals. In particular, he has assisted clients in industries such as pharmaceuticals, medical devices, software, luxury goods and apparel, consumer products, high-tech, chemical, automotive, entertainment, and trading houses. Jun has also supported clients with their needs for assistance in compliance (transfer pricing documentation), establishing transfer pricing policies, and determining tax effective supply chains.

Having lived overseas for more than 12 years during his youth, Jun is bilingual in English and Japanese. Jun has contributed articles in Tax Analyst, International Tax Review, and several major Japanese tax magazines, and has also co-authored in several books in Japanese regarding transfer pricing.