Shinsei’s vision is to contribute to the development
of the Japanese economy by supporting clients’ global activities
in the areas of international tax matters, financial affairs, and accounting.
Shinsei’s vision is to contribute to the development
of the Japanese economy by supporting clients’ global activities
in the areas of international tax matters, financial affairs, and accounting.
In terms of supporting many overseas operating companies and foreign-owned enterprises, we provide tax adviser, tax adviser, audit, preparing the local file, formation of trans pricing policy, preparation of CbC report and business summary, tax consulting mainly such as APA/ MAP support report, and trans pricing consulting services.
Handling the issue of international tax and accounting is very complicated because of being made a judgment after appropriate understanding of tax law of trading partner countries and tax treaty between them as well as Japanese tax law. We provide appropriate advice not only about Japanese tax law but about partner countries’ tax law by overseas member’s firms.
As the business-to-business transactions become more diversified and complicated, the range of the tax investigation change as well. With this trend taken into account, we provide a variety of support services for tax investigation.
We prepare a local file corresponding to transfer pricing taxation analyzing the detailed functions and risks of an overseas parent company and foreign related parties.
We analyze the basic facts such as an overview of related parties subject to analysis, capital ties, an overview of the group, organization structure, each company’s Profit/Loss Status, and overview of the industries you belong to, etc.
We understand the form of
transactions between related
parties and transaction flow,
transaction value, price
decision policy and price
negotiation process, etc. by
preparing sales channels.
We analyze the functions and risk of the related parties with whom to perform transactions of the analysis object.
Based on the above analysis result, we analyze the appropriate transfer pricing method for transactions of analysis object, the selection of comparable transactions and calculation of profit margin range, etc.
With documentation of analysis results as a local file, we prepare transfer pricing examination in Japan.
We create a transfer pricing policy to reduce the risk of transfer pricing taxation of the entire group.
(1) Create a draft of the transfer pricing policy
If a local file is already prepared, the draft of the transfer pricing policy is created based on the existing local file. If a local file is not prepared, the draft of the transfer pricing policy is created with minute analysis of function/ risk of a parent company and foreign related parties.
(2) Customizing transfer pricing policy
Based on the draft, the transfer pricing policy is customized so that it is established among controlled transactions in the entire group.
(3) Introduction of transfer pricing policy
Uniquely customized transfer pricing policy is explained to foreign related parties as to the entire group policy, where the transaction condition is changed following transfer pricing policy.
With an announcement of BEPS Action13, 2016 tax reform has required, a multinational enterprise with total consolidated revenue of JPY100 billion or more in the preceding year to prepare CbC report/ business summary report from the fiscal year starting on or after April 1, 2016.
Mutual Agreement Procedure(MAP) is an agreement between a tax authority in Japan and one in the partner’s country according to Tax Treaty, where MAP between countries or regions with whom Japan has not signed cannot be held.
Regarding transfer pricing taxation, MAP has two kinds of agreement, one for the elimination of double taxation and another about APA.
APA( Advance Pricing Agreement), which includes bilateral APA, multilateral APA in which MAP is necessary, and unilateral APA in which MAP is not necessary, is a system tax authorities examine and confirm the transfer pricing methods, etc. requested by a taxpayer.
We support APA/ MAP in cooperation with overseas specialists affiliated with us.
In terms of supporting many overseas investors who are currently facing the issues, we provide cross-border property planning services including mainly overseas asset reporting, inheritance/ gift tax of overseas asset, a letter”お尋ね“, audit, consulting of inheritance of overseas asset and, migration consulting.
We provide individual tax preparation services to customers who has business income or real property income who need to file tax returns in Japan. Our expert tax accountant will provide documentation support required in the preparation of various types of tax filing documents of various types such as income tax, overseas assets reporting.
We offer you with one stop service by our experienced expert tax accountant who will help you from consulting inheritance, collecting documents, appraising assets, assuring the value, to submitting the tax filing documents.
BPO is an abbreviation for Business Process Outsourcing that is an essential service for foreign-owned enterprises and domestic small and medium-sized enterprises. We provide BPO service including mainly a tax return, accounting report, entry service, payroll accounting service, and year-end tax adjustment.
We appropriately conduct agency functions for tax returns ( corporation tax, income tax, consumption tax, depreciable asset tax, etc.) with grasping of impact on the tax return by tax reform at every time that happens. Under the latest tax system, we provide the services for ideal tax returns.
Due to management checking against the business plan and budget plan, we liquidate and total up sales and expenses generated for a specified term. Because regular settlement every one month to six months makes a financial condition for the specified term clear, timely business judgment becomes possible utilizing it well.
We provide outsourcing of booking that is daily troublesome work such as input work of receipt with accounting software to make the accuracy of accounting higher and to smoothly perform financing and management as well as reducing your company’s business volume.
We provide payroll accounting service including totaling of time cards necessary to monthly payroll processing and updating information on joining and leaving the company as well as personnel changes.
Furthermore, it includes calculation of overtime payment, social insurance premium, employment insurance premium, income tax and resident tax as their amounts are variable and monthly accounting is necessary.
Under year-end Tax Adjustment, with totaling yearly payment and withholding tax,
the calculation of insurance premium and excessive and deficient is required. It is a merit of smoothly proceeding to ask for year-end tax adjustment together with payroll accounting service because it is the exclusive domain of certified tax accountant.
Shinsei International Tax Co.
(Certified Public Tax Accountant)
He mainly undertakes general tax accountant services and also specializes in transfer pricing consulting and international tax practice strategy consulting.
In Zeirishi-Hojin PricewaterhouseCoopers, he had wide-range experiences in the drafting of transfer pricing documents, the development of transfer pricing policies and so on. Moreover, he provides Japanese companies operating overseas with international tax practice strategy consulting services by utilizing his knowledge on transfer pricing and international tax practice.
Shinsei International Tax Co.
(Certified Public Tax Accountant・ U.S.C.P.A)
He compiled and reported consolidated accounting in Yamatake Corporation and was engaged in international tax practice and related tasks in regard to special purpose companies, investments from overseas and foreign corporations in Zeirishi-Hojin PricewaterhouseCoopers. Moreover, he was engaged accounting and tax practice in small and medium-sized enterprises and health-care corporations in Oyama Accounting Co. Ltd., to obtain the experience in accounting and tax practice in enterprises of various scales. He is engaged mainly in international tax practice and general tax accounting practice and is also willing to help a client improve its performance by utilizing his career in which he worked not only for accounting experts but also for private companies.
Shinsei International Tax Co.
(Certified Public Tax Accountant)
Entering the TRTB as a national tax expert, he was engaged in official works on Transfer Pricing fields, such as handing of Mutual Agreement Procedures (MAP) ot the NTA, surveys, Advance Pricing Arrangement (APA) examinations, court cases, and tax reform, for 11 years.
After registration of a certified public tax accountant in June 2017, he has been making tax consultations dedicated to transfer pricing. Also he teaches in many different seminars such as business research seminar and seminar at Mizuho Research Institute Ltd.
He wrote a book titled “How to prepare Transfer Pricing Documentation（2nd ed.）” (published by Chuo Keizai-sha in December 2018), and “Transfer Pricing Practices Q&A” (published by Seibun-sha in March 2020).
Shinsei International Tax Co.
Adviser・ Certified Public Tax Accountant
〈books〉
「三訂版源泉所得税の誤りが多い事例と判断に迷う事例」（大蔵財務協会）
「新訂版税目別誤りが多い事例と判断に迷う事例」 (大蔵財務協会)
「中小企業者のための費用の取扱い」（大蔵財務協会）
「実務家のための外国税額還付の手引書」（大蔵財務協会）
「海外取引と最新の税務調査対策」（大蔵財務協会）
「実務家のための図解によるタックス・ヘイブン対策税制」（法令出版）
Shinsei International Tax Co.
(Business Document Consultant)
In Seiko Epson Corporation, he was engaged in the following projects: 1) international tax practice work around transfer pricing, 2) general work in book closing and accounting around overseas transactions, 3) financing work such as fund raising and administration and 4) development of intermediate-term management plans, dealing with M&A and the introduction of a new accounting system. Thereafter, he set up his own practice as a business document consultant with an administrative scrivener’s license.
He is willing to support his client’s business activities by utilizing his career on transfer pricing and international tax practice from the standpoint of private companies.
