Under the current economic climate, enterprises operating in Japan may need to restructure their organizations, undertake new investments or wind up certain business lines. Our Business Tax Advisory professionals draw on their diverse perspectives, skills and experiences to provide Japanese tax advisory services catered for your specific business tax needs. It is important to analyze the tax costs associated with such activities and identify efficient tax structures during the planning stages. Further, considering the impact of the rapidly evolving Japanese tax environment on corporate restructuring and investment, it is also worthwhile to be well informed on tax reforms promptly. Our team will actively provide tailored tax advice and solutions to your enterprise, bearing in mind your business objectives.
Another area in which our team focuses is tax advisory services for real estate investments, including acquisition of real estate holding companies. Our real estate business group provides tax services relating to structuring real estate investments, such as J-REIT and private real estate funds, as well as advising on various steps of structure implementation.
Through these services, the Ernst & Young Business Tax Advisory team will support you in the proactive management of tax issues arising from your operations.
When conducting group restructuring (including adoption of consolidated tax filing) and intercompany transactions, it is important to confirm the tax consequences and consider any tax related costs. Preparatory analysis and planning can help build a tax efficient structure and avoid unanticipated tax exposure.
It is necessary to understand the tax implications of new transactions, investment and business closures to form an efficient tax strategy. We analyze and consider the overall tax impact of a transaction, including not only taxes levied on income but also applicable consumption tax and other indirect taxes.
In preparing for tax audits or inquiries from the tax authorities, it is important to be in a position to substantiate past transactions with supporting documents and explain transactions to the tax examiners sufficiently and appropriately without causing any misunderstanding. Our advisory group offers services that can assist you in such matters.
To structure investments in real estate (including securities backed by real estate) in a tax efficient manner, it is essential to consider the tax consequences to both the investment vehicle, such as a tokutei mokuteki kaisha (TMK) as a special purpose company under the Asset Liquidation Law or a tokumei kumiai (TK), an anonymous or silent partnership under the Commercial Code, and the investors in the real estate fund. We assess the tax risks and implications in Japan, propose a tax efficient structure considering the investor’s tax residence, and offer advice on various transactions rendered by real estate funds.
Kenji Ueda Partner, International and Transaction Tax Services Tel: +81 3 3506 2467
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