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International Taxation

Anderson Mori & Tomotsune has enjoyed a long-standing reputation with numerous international corporate clients for the quality of our tax services. In particular, our international clients appreciate our strategic advice on their inbound investments, establishment of subsidiaries, branches, representative offices and other business bases in Japan, and tax concerns regarding their expatriate employees.


Our advice on both inbound and outbound deals encompasses the whole range of issues. From structuring and restructuring strategies to the review of contractual terms, our lawyers are well versed in current tax issues, including issues relating to thin capitalization rules, earnings stripping rules, transfer pricing rules, anti-tax haven rules (CFC rules), the securities taxation system and other important international taxation rules and systems. Additionally, we advise clients on how to deal with possible tax inspections by, or disputes with, the tax authorities. Further, we are frequently called to interpret the provisions of tax treaties, which have become increasingly sophisticated and complex and raise difficult questions as to how they should be practically applied.


We also regularly advise on matters of Japanese taxation in overseas restructuring deals, such as cases involving multiple investment trusts, partnerships or other entities that are established overseas.


Our advice is often sought by outside professionals, including foreign law firms, tax accountant corporations and tax accountants. In many multi-jurisdictional transactions, we also coordinate with foreign tax advisers to achieve successful outcomes for your clients.

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