Variety of Japanese tax consulting for corporate clients

Premier Tax & Advisory provides a wide range of Japanese and international tax services for corporate clients doing businesses and/or investments in Japan. We support all phases of businesses in Japan including initial investment, setting up an entity, expanding operations, M&A and reorganizations, restructuring and repatriation of profit regardless of the size of businesses and investments.

We have assisted both publicly and privately owned companies and groups, from a wide range of business sectors, across a broad suite of tax services and technical specialisms.
We help our clients develop efficient and cost-effective tax structures and manage their tax risk and processes. Our advice ranges from tax compliance to advising on international structuring, cross-border transactions, employment taxes, VAT, variety of tax incentives.

Running a successful business is no easy feat at the best of times and ensuring that your company or group is compliant and tax-efficient is essential to maximise shareholder value. We help our clients with strategic tax planning, ensuring that full advantage is taken of all available reliefs and compliance risks are identified and resolved.

We provide comprehensive, robust and considered advice on all aspects of corporate tax, including mergers and acquisitions, reconstructions and reorganisations, advice on areas of potential dispute with National Tax Authorities and on the most tax-efficient manner of extracting profits and achieving business objectives.

Whether the business is large or small, privately held or public, single or multi-state, domestic or multi-national, our experienced professionals will provide superior compliance, consulting, and planning services including the following:

Examples of our services

■Advisory and planning

  • Setting up a tax-efficient entity in Japan considering tax-efficient ownership and capital/debt structure
  • Development of tax-efficient management and operational structure
  • Tax treaty planning and interpretation including permanent establishment (PE) determinations, limitation on benefits determinations and reducing or eliminating withholding taxes
  • Tax-effective financing considering limitation of interest deductibility; thin capitalization rules and earnings stripping rules
  • Corporate tax incentives and efficient use of foreign tax credits
  • Cash repatriation structure and tax-efficient cash redeployment
  • Value chain transformation / global business model optimization
  • Japanese CFC rules
  • M&A, Group reorganization and corporate restructuring
  • Capital restructuring: capital reduction, debt-equity swap (DES), debt forgiveness
  • Transfer pricing policy and documentation
  • Tax advice on foreign executives who live and work in Japan, including expatriation tax issues, tax residency issues and tax filing obligations
  • Tax efficient compensation for directors and employees
  • Tax rulings

■Compliance

  • Filing of annual tax returns and statutory reporting
  • Mandatory tax representation service for non-residents
  • Communication with the tax authorities on your behalf
  • Representation during tax audits and investigations and dispute resolution
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