Cross-Border
&
Globalization

My name is Fumito Tanaka, as Japanese licensed tax accountant, and the name of my tax firm is “Japan Tax Advisor” (hereafter JTA). With the extensive experience I have gained at Big 4 accounting firms in Japan and Singapore, coupled with JTA’s network of professional relationships. JTA is well-equipped to assist you with business development initiatives from overseas into the Japanese market.

JTA’s expertise includes tax filing, providing tax advice, and facilitating mergers and acquisitions (M&A) for corporations and individuals in English.

MISSION

We understand that there are not many Tax Advisors who can communicate in English in an environment where communication with experts is essential when considering business expansion and investment in Japan. Under these circumstances, we believe that the most important mission of JAT is to support the entry of foreign capital (business/investment) into the Japanese market by lowering the hurdles to business expansion in Japan.

Communication

Aptitude to build good relationships with clients through communication.

JAT is good at communicating with clients, understanding their challenges and then proposing support to help them solve them.
They also possess the qualities that enable them to build good relationships with clients, such as close communication, an ease of speaking to build trust, the ability to understand things of meeting a wide variety of clients throughout their careers.

Globalization

Global Japanese tax advisor who can speak English.

JTA specialise in providing support to clients who face the challenge of English and tax hurdles, including Japanese tax advisory in English and communication with overseas advisers.

Career

More than 12 years' experience with Big 4 Tax firms

More than 12 years’ experience in tax advisory and tax filing, including overseas assignments in the Big 4 tax firms.
The quality of delivery by JTA should be ensured by the achievement of the title of Senior Managers in my last position at a Big 4 tax firm.

Relation

Extensive contacts with Japanese and foreign accounting, tax, legal and other professionals, wealth management and M&A advisors.

As JTA area of expertise is taxation, he is able to assist clients in resolving issues through his own relationships with appropriate and trusted advisers in Japanese accounting and legal matters and local accounting, taxation and legal matters outside Japan.
JTA also maintains relationships with leading wealth management advisors and M&A specialists, collaborating as needed to support clients in addressing their needs and challenges.

SERVICES

JTA can provide the following services in English.

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Supports for Going to Japan Market

For clients considering expanding into Japan, we review and advise on the tax implications and optimal tax structuring for the envisaged business.
Advice is given to ensure that the subsidiary is an Activity that does not qualify as a Permanent Establishment (“PE”) in Japan of the parent company.
If working capital, etc. is provided by a foreign parent company or a foreign related company to the Japanese company by way of loans rather than equity, the thin cap rule and the earning stripping rule need to be taken into account.
JTA　can collaborate with a range of advisors to facilitate the establishment of the company in Japan and　support subsequent tasks, such as bookkeeping and the calculation of tax accruals etc.

Corporate Taxes Compliance Services (For Business)

If you have a legal entity in Japan, you are required to file corporate tax, National local corporate tax, Inhabitant tax and Enterprise tax returns.
In some cases, a consumption tax (VAT) filing is also required.
If you have certain depreciable fixed assets, a depreciable fixed asset tax return will also arise.
Stamp duty must be paid when concluding contracts on certain details (but is not required in the case of electronic contracts).
In addition, tax audits are generally carried out by the tax authorities every few years.
JTA can support these tax compliance (including bookkeeping where necessary) required for doing business in Japan.

Supports for Tax Compliance (For Property Investment)

Explore the most appropriate investment structures (including TK-GK structures etc.) for foreign investment in Japanese property.
When an investment structure has been decided upon, the company provides support with bookkeeping, tax filing and cash management for property investments.
For legal procedures, we can introduce you to appropriate legal advisor who can manage English communication.

Tax advice for cross-border transactions

Cross-border payments of, for example, dividends, interest and royalties to the parent company require the payment of withholding tax (“WHT”).
The WHT rate is 20.42% under domestic rule, but if you are a tax resident of a tax treaty country with Japan, the rate may be reduced or exempted with a submission of tax treaty notification.
In some cases, the sale of Japanese real estate and certain shares owned by non-residents may require a tax filing in Japan.
JTA can provide advices on these and other cross-border Japanese tax implications, as well as assistance with tax returns and payments (implementations).

Japanese Consumption Tax for Cross-border supplies of electronic services.

If a foreign company (non-Japanese resident) provides cross-border supplies of electronic services (i.e. game distribution, services that allow customers to use software or databases in the cloud, distribution or posting of advertisements via the internet, etc.) to Japanese customers from outside Japan (in the case of B to C), it will be required to file a consumption tax return in Japan even if it has no office (PE) in Japan, you may need to file a consumption tax return in Japan even if you do not have any PE in Japan.
We can provides assistance with consumption tax filings and payments in relation to these.
Reference:　https://www.nta.go.jp/english/taxes/consumption_tax/cross-kokugai-en.pdf

Communication Supports with Your Advisor

Assistance with regard to English communication with the appointed tax adviser.
For example, if you have already appointed a Big 4 as your tax adviser and your Japanese resources cannot handle the submission of materials for the preparation of tax returns requested by the Big 4, JTA can also support you in the preparation of the submission materials instead of your resources.

Finance and Tax Due Diligence of Japanese Targets

If Finance & Tax Due Diligence is required for the acquisition of a Japanese company, JTA can provide it to the target company and provide a report in English (as buy-side advisor).
In addition, we can also assist with sell-side due diligence, tax structuring, review of SPAs (share transfer agreements), post-merger integration support and advisory tax advisers to the acquiring company.

About JTA

Head of Japan Tax Advisor
Licensed Japanese Tax Accountant

Fumito Tanaka

I am a Japanese certified public tax accountant and the head of the tax firm ‘Japan Tax Advisor.’ With almost 14 years of extensive experience in providing international corporate tax services at Big 4 firms, my background includes nearly 5 years at PwC Tax Japan, 3 years at PwC Tax Singapore as a secondee, and 4 years at KPMG Tax Japan, along with 2 years at a mid-sized accounting firm. My final title at PwC Japan was Senior Manager.
During my tenure at PwC Tax Japan, I developed strong expertise, particularly in M&A (for both buyers and sellers), international tax (both inbound and outbound), and tax advisory services, such as tax treaty analysis, advice on cross-border transactions and reorganizations, and Japanese CFC analysis.
Additionally, I have experience in providing Japanese clients with international tax advisory services, which includes guidance on withholding taxes, permanent establishment, and Japan’s controlled foreign company (CFC) rules, particularly in relation to pre-closing and post-M&A transactions.
From August 2019 to August 2022, during my secondment in Singapore, I collaborated with the local team to offer a wide range of tax services to Japanese companies. This included corporate tax, stamp duty, and GST, encompassing tax due diligence, tax structuring, applications for Singapore tax incentives, and support for tax audits in the Southeast Asia region.
Furthermore, I have experience in providing Japanese tax advice to non-Japanese clients in English, which involves preparing reports and engaging in verbal communication during calls.
I possess strong communication, leadership, and interpersonal skills in both Japanese and English.

Career

2009
Justice accounting and tax office in Tokyo : Provide tax and accounting advisory services mainly to SMEs and wealthy individuals.

2011
KPMG Tax Japan : Providing preparation tax returns and advisory services to Japanese listed companies and major foreign companies.

2015
PwC Tax Japan: He worked for major Japanese companies, funds and large foreign companies in tax advisories mainly related to M&A tax and international tax.

2019
PwC Tax Singapore (Secondment) : Promoted to senior manager there in 2021.

2022
PwC Tax Japan : Returning to PwC Tax Japan as a senior manager, he has been involved in very large M&A tax transactions, tax advisory work (including PMI work) and non-Japanese tax advisory work in English.

2023
– Retire from PwC Tax Japan and establish “Japan Tax Advisor”.

Bachelor of Economics, Rikkyo University
Licensed Japanese Tax Accountant