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TK Global Transaction Advisory Co., Ltd.

Our transfer pricing team with extensive experience in helping multinational corporations address their transfer pricing issues provides advisory services.

Our transfer pricing team with extensive experience in helping multinational corporations address their transfer pricing issues provides advisory services.

Transfer pricing issues have been spotlighted worldwide following a number of cases in which a number of multinational corporations with global operations have manipulated transfer pricing to transfer their income to countries with excessively low tax rates in order to reduce their tax burdens. The Organization for Economic Cooperation and Development (OECD) announced its Base Erosion and Profit Shifting (BEPS) Action Plan to create an international taxation framework in order to ensure fair taxation. Many countries around the world have taken action to organize their domestic tax regulations in compliance with this plan, and this trend continues to be in place today.

This global movement to strengthen compliance regarding transfer pricing has led to a rise in potential taxation risks at multinational corporations. For those corporations that place importance on their accountability to their shareholders, action on transfer pricing has become an important management issue that they no longer can afford to ignore, regardless of the size of the corporation in question.
In addition, information pertaining to international taxation including transfer pricing is attracting interest as part of ESG (environment, social, and governance) data. In view of the fact that ESG-conscious management has become essential today in achieving long-term business growth, development of policies having outstanding transparency regarding transfer pricing has become an urgent issue.

Tokyo Kyodo Accounting Office offers transfer pricing advisory services that pay attention to practical issues and trends in transfer pricing audits in the evolution of systems in response to the growing complexity of schemes in Japan and other countries. In collaboration with RSM International, the sixth largest international network of accounting firms in the world, we offer transfer pricing advisory services while viewing transfer pricing issues as management issues, after accurately analyzing and assessing the transfer pricing issues of our clients and engaging in discussions with them on what would be ideal.

Services

We offer a diverse menu of transfer pricing services tailored to our clients’ needs.
We also offer a free meeting for the first time only. Please contact us for more details.

  • Transfer pricing risk assessment

    Providing quantitative and qualitative analysis and assessment of transfer pricing risks associated with controlled transactions and proposing a transfer pricing policy to be implemented depending on the circumstances of client.

  • Transfer pricing analysis on price setting in controlled transactions

    Transfer pricing analysis on price setting in controlled transactions that will be executed in the future or that were executed in the past

  • Transfer pricing documentation support aligned with BEPS action plan

    Support for the preparation or update of the Master File (MF), the Country by Country Report (CbCR), and the Local File (LF), which is required under transfer pricing regulations

  • Transfer pricing policy development and implementation support

    Support for the preparation and implementation of a document (transfer pricing policy) that outlines guidelines and internal rules regarding the pricing of controlled transactions for the purpose of Plan, Do, Check (PDC) management.

  • Application support for Advance Pricing Agreements (APAs)

    Support for bilateral or unilateral APA filings to avoid the risk of costly and burdensome tax audits by responding to transfer pricing issues in advance.

  • Support for mutual agreement procedures

    Support for obtaining advance pricing agreements (APAs) and support for requesting relief for double taxation relating to transactions between Japan and another country.

  • Valuation services for tax purposes

    Support for the calculation of consideration for the transfer of businesses, intangible assets, etc.

  • Advisory contract for transfer pricing consultation

    Advisory services such as providing answers to general transfer pricing consultations and information on transfer pricing regulations in other countries through RSM International.

  • Financial transfer pricing advisory services

    Advisory services concerning financial service transactions carried out by banks, securities companies, etc., and financial transactions carried out by business companies (lending, guarantee, cash pooling, captive insurance, etc.)

The Strengths of Our Services

  • We have many years of experience in handling transfer pricing issues in various industries such as manufacturing and financial services in the TP team of the Big 4, and provide practical and high quality services tailored to each client’s situation.
  • In-house transfer pricing experience in a large Japanese multinational company.
  • Leading accounting firm in Japan with the most know-how and experience in transfer pricing advisory services for financial transactions

The Strengths of Our Services

  • We have many years of experience in handling transfer pricing issues in various industries such as manufacturing and financial services in the TP team of the Big 4, and provide practical and high quality services tailored to each client’s situation.
  • In-house transfer pricing experience in a large Japanese multinational company.
  • Leading accounting firm in Japan with the most know-how and experience in transfer pricing advisory services for financial transactions

Features of our services

1
Global network

Leveraging the close relationship with the international accounting firms that are members of RSM International, the sixth largest international network of accounting firms in the world, through the exchange of information on transfer pricing and joint operation of transfer pricing projects, we aim for a further leap forward. In particular, as a related party may have an impact on multiple countries in a transfer pricing project, we provide high value-added services by leveraging the global network mentioned above.

2
Global reputation

In the world transfer pricing ranking announced by International Tax Review, we have been rated and ranked highly every year since the year of entry as a leading Japanese firm for our strong expertise and high client satisfaction.(*)
We provide high value-added services to clients and markets around the world.
* Tier 2 in 2024 World’s Leading Transfer Pricing Firms Asia (Japan)


Experienced professionals

The core members of the TP team are professionals who have worked in the transfer pricing teams of the Big 4 for more than 10 years, and have experience in transfer pricing advisory in a variety of industries. With regard to financial transfer pricing, we have some of the best advisory experience in Japan, not only for financial services by financial institutions but also for financial transactions by business corporations. Our strength lies in our expertise in financial transfer pricing, which is said to be rare even among major international accounting firms.

The core members of the TP team are professionals who have worked in the transfer pricing teams of the Big 4 for more than 10 years, and have experience in transfer pricing advisory in a variety of industries. With regard to financial transfer pricing, we have some of the best advisory experience in Japan, not only for financial services by financial institutions but also for financial transactions by business corporations. Our strength lies in our expertise in financial transfer pricing, which is said to be rare even among major international accounting firms.

Experts

Shintaro Kosaka

Shintaro Kosaka

Transfer Pricing Advisory Group
Leader / Executive Vice President and Director

Hirotsugu Watanabe

Hirotsugu Watanabe

Transfer Pricing Advisory Group
Manager/Director
Head of Western Japan Region

Company profile

Company name

TK Global Transaction Advisory Co., Ltd
President and Representative Director Ryutaro Uchiyama

Description of business

Consulting services for Global Transactions, etc.

Overseas network

RSM International (Correspondent Firm)
※Member as a joint Tokyo accounting firm

Location

Kokusai Building, 3 1 1 Marunouchi , Chiyoda ku , Tokyo, Japan
West Japan (Osaka) Office: 4 34 Hiroshiba cho , Suita shi , Osaka(Esaka Daiichi Building 6F)

Contact us

+ 81-3-5223-9570

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