Annual Tax Reform 2019 & beyond: Insights into the Japanese Tax landscape and a look into future global changes


IBA Japan SeminarTax

This seminar is the second part of our Tax 2019 series, and will complement the session taking place on March 1st.

In this seminar, Mr. Jonathan Stuart-Smith, Mr. Ichiro Suto, Partner, and Mr. Yasunari Nakayama, will discuss the 2019 Tax Reform released on December 21st, 2018, and update members on key changes affecting financial services firms. The presentation will also expand on the developments in Tax related issues and explore international developments impacting the industry and members. The seminar will include:

  • Discussion of the new Japanese earnings stripping rules and their implications for financing structures in Japan.
  • An update on Japanese Transfer Pricing trends.
  • A brief overview of the other changes in the 2019 Japan tax reform.
  • A discussion of future changes in the global tax landscape, including the OECD’s proposed radical changes to the taxation of the digital economy.

Jonathan Stuart-Smith
Partner, International Tax Services

Background & Qualifications

►International Tax Services Leader, Japan

►Asia Pacific Tax Leader, Japan Business Services

►Over 25 years of tax experience, including 15 years based in Tokyo

►Has also lived and worked in London (10 years), Hong Kong (2 years) and Singapore (3 years)

►BA (Hons) Industrial Economics, University of Nottingham, England

►Chartered Accountant (England and Wales)

Skills & Expertise

►Specializes in International Tax and practices in the areas of corporate structuring, M&A, reorganizations, financing, supply chain, intellectual property and tax treaty analysis

Relevant experience

►Jonathan serves as the Global Tax Account Leader for a major Japanese automaker.  He also serves the Japanese subsidiaries of foreign-owned automotive OEMs.  His experience in the auto sector includes entity establishment, structuring, transfer pricing policy and documentation, APAs and tax controversy.

►Advises multinational companies across  sectors including life sciences, technology and real estate

Ichiro Suto
Partner, International Tax Services - Transfer Pricing

Background & Qualifications

►Ichiro Suto is a tax Partner with Ernst & Young Tax and the leader of Transfer Pricing Division in International Tax Services.

►He joined EY, Tokyo office in October 2012.

►Before joining EY, he was a Managing Director, the head of Tax Department at Morgan Stanley MUFG Securities Co., Ltd., responsible for the tax risk management for the financial products/advisory offered to its global clients and the tax compliance/planning on the corporate side.

►Before Morgan Stanley, he was with Arthur Andersen for 12 years, including experience in Transfer Pricing.

►He graduated from Hitotsubashi University.

Skills & Expertise

►Certified Public Accountant (Japan and California)

Relevant experience

►His coverage and experiences at Morgan Stanley MUFG Securities Co., Ltd. included the tax advisory on product development for corporate finance, securitization, M&A, structured products, real property funds, hedge funds, distressed debt investments, etc. On the corporate side, he was responsible for US tax planning including tax efficient capital repatriation planning, transfer pricing in addition to the Japanese tax compliance and planning.

►His focus is on international and Japanese tax advisory services for both inbound and outbound financial institutions.

Yasunari Nakayama
Associate Partner - Financial Services

Background & Qualifications

►Yasunari has over 20 years of tax professional experience, starting with one of major tax accounting firm in Tokyo, mostly in financial services industry.

►Of his career, he had 15 years spent as an in-house tax director of the European financial institution, responsible in North Asia including Japan and Greater China. In this experience, his responsibility included management and oversight of regular tax compliance, tax audits on direct and indirect taxes including conflict resolutions, as well as transaction and operational tax advisory, and oversight of tax accounting. His responsibilities also included transfer pricing where he was a core member of the team in completing the former employer’s trilateral APA.

Skills & Expertise

►Bachelor of Business, The University of Queensland, Australia, 1996

►Tax advisory for restructuring, such as acquisitions or dispositions of particular business lines and post-merger integration in case of acquisition

►Tax advisory on centralization of loan portfolio, assigning loans from multiple locations to the central lending facility

Relevant experience

►Regional lead in entity rationalization in APAC region, where centralization of business activities that are conductible under same license into same operating entities, migrating ownership of operating entities under most efficient holding companies, and liquidating remaining entities

►Regional advisor for centralization of loan portfolio to a central lending entity, including novation of loan portfolio, implementation of transfer pricing regime to remunerate activities of originating entities, as well as allocating certain costs associated with macro hedge of credit risk for residual loans left at the original locations.

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