PRACTICE AREAS

Litigation and Other Forms of Dispute Resolution Tax Disputes

In current tax disputes there is a trend of large-scale cases such as an increase in lawsuits involving tens of billions of yen and big companies vigorously contesting taxation.  Behind this trend are the tax authorities aggressively taxing entities especially focusing on international taxes, whereas corporations are hesitating to simply file amended returns since they fear the risk of shareholder suits.  Also, similar to foreign corporations, the fact that more domestic corporations are actively working on tax planning is another factor behind this trend.

In responding to audits, we understand the thinking of the relevant tax authorities in such audits and respond effectively.  For example, our services include providing advice on strategies to avoid taxation by successfully arguing our client corporations’ viewpoints by submitting tax summaries and facts, attending audits, preparing for anticipated questions and planned answers for such audits, drafting statements of facts, collecting evidence and other related services.  At TMI, we handle responding to corporate audits regarding international taxation, including transfer pricing tax and withholding tax related to royalties, and the corporate reorganization taxation system.

Also, as for audits related to inheritance of high net worth clients, we work to avoid taxation by thoroughly explaining the formulated tax plan to the tax authorities.

In filing appeals, requests for review and tax litigation, we are devoted to finding effective arguments and evidence by thoroughly researching precedents, coming up with theories to eliminate taxes and making aggressive efforts to get hearings for the parties concerned to better understand the circumstances.

TMI has a proven track record in handling audits and tax disputes, such as winning reversals in transfer pricing and inheritance tax audits resulting in billions of yen tax reductions, winning overall victories in actions to vacate administrative orders regarding corporate income tax of billions of yen and so on.

PAGE TOP