Issues of reorganization tax, real estate transfer tax and value-added tax, including related strategic tax planning issues, generally play an important role in reorganization/restructuring transactions. Recognizing the many different tax pitfalls that clients may encounter in reorganizations/restructurings under income tax law or real estate transfer tax law is critical to avoid unwanted tax liability. In many cases, transaction structures, though permitted under corporate law, trigger unnecessary tax liabilities, and alternative structures should be implemented.
Premier Tax & Advisory offers advice on group-wide onshore and offshore reorganizations under the complex Japanese tax laws. We apply broad range of legal and tax knowledge and experience to evaluate all possible opportunities, challenges and risks inherent in corporate reorganizations and help companies design and implement the best structure that support objectives, optimize opportunities and minimize tax liabilities. Since reorganization projects often involve corporations with multiple layers of subsidiaries in different countries, we can collaborate with an expert team of attorneys and tax advisors in different countries.
Examples of our services
■ Corporate Reorganization
- Tax structuring of group reorganization for tax minimization
- International tax structuring for reorganization even considering global value-chain optimization
- Tax-qualified reorganization and non-qualified reorganization
- Evaluating and looking at options for the transfer pricing framework
- Preparing the step-by-step process for completing the transaction
- Planning for future flexibility: future acquisitions, debt servicing, returns to shareholders and a potential future exit
- Post-reorganization service
- Utilization of tax losses and unrealized losses
- Statutory filings of reorganization
- Transfer pricing documentation
- Cash repatriation