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TK Global Transaction Advisory Co., Ltd.

Specialized Tokyo Kyodo Accounting Office teams for the transfer price taxation system, with extensive experience in global corporations dealing with transfer pricing, offer strategic advisory services.

Specialized Tokyo Kyodo Accounting Office teams for the transfer price taxation system, with extensive experience in global corporations dealing with transfer pricing, offer strategic advisory services.

In recent years, there have been a significant number of cases in which multinational corporations with global business operations have transferred income in excessive volume to countries with low tax rates by means of manipulating transfer prices for the purpose of cutting down their tax burdens. For this reason, issues related to transfer pricing have attracted global attention. The Organization for Economic Cooperation and Development (OECD) announced its Base Erosion and Profit Shifting (BEPS) Action Plan in order to ensure fair taxation. Many countries have taken action to organize their domestic laws in compliance with this plan.

 

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 its shareholders, action on transfer pricing has become an important management issue that they no longer can afford to ignore.

In addition, information pertaining to international taxation including transfer pricing is attracting interest as part of the 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 strategic transfer pricing advisory services with attention to practical issues and trends in transfer pricing investigations in the evolution of systems in response to the growing complexity of schemes in Japan and other countries. We offer strategic transfer pricing advisory services in which matters related to transfer prices are perceived as a management issue, by making active use of our overseas partner offices (RSM International), accurate analysis and assessment of matters pertaining to transfer prices for our clients, and engaging in discussions on the ideal image.

 

 

Financial transactions conducted by business companies (financial loan transactions, liability guarantee entrustment, cash pooling, captive insurance, etc.) have not been governed by guidelines under the transfer pricing taxation system in the past. With the announcement of the OECD Transfer Pricing Guidance (hereinafter called “Guidance”) in February 2020, followed by its revision as the OECD Transfer Pricing Guidelines (hereinafter called “OECD Guidelines”) in January 2022, changes have been applied to these financial transactions. In addition, the announcement of the revision of Japan’s Commissioner’s Directive on the Operation of Transfer Pricing (hereinafter called “the TP Directive”) to reflect the OECD Guidelines has increased the need to conduct transfer price analysis based on the OECD guidelines and the TP Directive, conduct reviews on price settings, and take action in response to the transfer pricing investigations.

 

The OECD Guidelines and the TP Directive show practical details on methods for analysis regarding interest and guarantee rates pertaining to the aforementioned financial transactions conducted most frequently especially among business companies. In the future, the tax authorities are expected to further intensify their transfer price investigations in relation to financial transactions, raising transfer price taxation risks for these transactions at business companies.

The Strengths of Our Services

  • Counseling from the three perspective of risk management, compliance, and opportunity
  • Experts possessing broad ranging knowledge not only of transfer pricing taxation but also in-house practical experience in transfer pricing, financing, and other items will provide support to resolve issues from the client’s standpoint
  • Prominence in possessing the industry’s top know-how and experience in advisory services for transfer pricing in financial transactions

The Strengths of Our Services

  • Counseling from the three perspective of risk management, compliance, and opportunity
  • Experts possessing broad ranging knowledge not only of transfer pricing taxation but also in-house practical experience in transfer pricing, financing, and other items will provide support to resolve issues from the client’s standpoint
  • Prominence in possessing the industry’s top know-how and experience in advisory services for transfer pricing in financial transactions

Counseling in transfer pricing for financial transactions
Features of our services

1
Risk management

We offer proposals on practical transfer pricing action through quantitative and qualitative assessments of transfer pricing taxation risks in group financial transactions.

 

The risk of transfer pricing taxation in group financial transactions is assessed accurately with attention to financial markets worldwide and transfer pricing taxation systems for financial transaction in various countries, and reports are then drafted accordingly. Proposals for specific action to be implemented in the face of recent trends in statutory laws and research are offered by systematizing the client’s current status and future vision through dialogues.

 

■Assessment of transfer pricing taxation risks and drafting of a report reviewing countermeasures

■Establishment of transaction prices adapted to the transfer pricing taxation system and support in defining the basis for such price settings
(Includes calculation of interests and liability guarantee fees through benchmark analysis, etc.)

■Development of transfer pricing policy and support in implementation

■Support in application and acquisition of advanced pricing agreements (APA)

2
Compliance

Tokyo Kyodo Accounting Office will produce documents and other items required by transfer pricing taxation systems in Japan and other countries.

 

Our services are not limited to the creation of local files as part of the minimum requirements in compliance with statutory taxation requirements but also provide support in taking strategic transfer pricing action targeted towards lowering risks and taxation costs.

 

■Production/update of transfer pricing documents (local files, memos, etc.)

■Support in preparation of documents for strategies in response to transfer pricing investigations/Q&A

■Simulated investigation pertaining to transfer pricing

■Transfer pricing investigations support


Opportunities

We provide support in the review, introduction, and implementation of opportunities that contribute to the client’s business management.

 

We offer practical advice based on in-depth knowledge in highly sophisticated and complex financing and on practical experience in leading-edge financial transfer pricing.

 

■Support for a review of transaction prices that both minimizes transfer pricing risks and optimizes the taxation cost

■Support for the introduction and optimization of global cash pooling

■Support for the development and improvement of business flows related to group financing

We provide support in the review, introduction, and implementation of opportunities that contribute to the client’s business management.

 

We offer practical advice based on in-depth knowledge in highly sophisticated and complex financing and on practical experience in leading-edge financial transfer pricing.

 

■Support for a review of transaction prices that both minimizes transfer pricing risks and optimizes the taxation cost

■Support for the introduction and optimization of global cash pooling

■Support for the development and improvement of business flows related to group financing

Experts

Shintaro Kosaka

Shintaro Kosaka

Transfer Pricing Strategy Consulting
Executive Vice President and Director

Hirotsugu Watanabe

Hirotsugu Watanabe

Transfer Pricing Strategy Consulting
Director

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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