Services

From tax audit defense to legal opinions, tax appeals, and tax litigation

Deloitte Tohmatsu is chosen by clients for its track record of resolving differences of opinion with tax authorities

Differences of opinion often arise during tax audits because of the conflicting interests of taxpayers and tax authorities. Deloitte Tohmatsu accordingly examines the causes of disagreements, explains to taxpayers the prospects that their views will prevail and the procedures and costs entailed, and provides comprehensive services ranging from tax audit defense to legal opinions, tax appeals, and tax litigation. We are chosen for our track record of resolving disagreements with tax authorities.

We provide a comprehensive end-to-end service to resolve tax controversies

When a taxpayer is faced with a difference of opinions with the tax authorities during a tax audit, a legal opinion can be the taxpayer’s trump card. Increasingly, there are cases where taxpayers’ opinions are accepted earlier due to the taxpayer filing a legal opinion explaining the detailed rationale for why the taxpayer’s opinion should be accepted, together with supporting evidence. When a difference of opinions is not resolved during a tax audit, the taxpayer may file a tax appeal and seek a final decision on the matter by the administrative branch. The tribunal will issue a decision based on evidence, hearing from both sides in detail. Engaging in tax litigation can also enable the taxpayer to correct an erroneous legal interpretation.

We examine the cause of the difference of opinions, provide consultation on the chances of having the taxpayer’s opinion accepted as well as the procedures and costs it will take, and use our strong credentials to assist in performing the required procedures from defending a tax audit to filing a legal opinion and representing you in tax appeal and litigation.

>> Click [Legal Opinion, Tax Appeal and Litigation Service] for more details

 

We have strong credentials for resolving differences of opinions with the tax authorities

There are numerous examples where our clients’ opinions were accepted. Recent examples include the following.

2024

  • Tax litigation regarding denial of act or calculation of corporate reorganization
  • Tax appeal against the revocation of blue form tax return approval
  • Legal opinion regarding the CFC regime
  • Tax appeal regarding property tax

2023

  • Legal opinion regarding bad debt losses and losses on sale of receivables
  • Legal opinion regarding taxation on entertainment expenses
  • Legal opinion regarding denial of act or calculation of corporate reorganization
  • Legal opinion regarding an advantageous placement of shares
  • Tax litigation regarding the CFC regime

2022

  • Legal opinion regarding property tax
  • Tax appeal regarding deemed capital gains
  • Tax appeal regarding corporate gains on donations
  • Legal opinion regarding deemed capital gains

2021

  • Tax appeal regarding corporate reorganization

2020

  • Legal opinion regarding stamp tax

 

 

Tax Controversy Japan Updates

This article provides an overview of areas of focus and the tax audit and controversy procedure in relation to national tax (excluding customs duty) in Japan.

>> Click [Tax Controversy Japan Updates] for more details

 

Professionals in charge

Yutaka Kitamura

Yutaka Kitamura

DT Legal Japan, Attorney-at-law in Japan and the State of NY

Practice Yutaka Kitamura serves as Tax Controversy Leader from June 2024. There are numerous examples where his clients’ opinions were accepted. Recent examples of successful cases where his clients’ ... More

Hiroki Yamakawa

Hiroki Yamakawa

Deloitte Tohmatsu Tax Co. Senior Advisor

During his over 30-year service at the NTA, Mr. Yamakawa assumed key positions such as Director of the Office of Mutual Agreement Procedures and Director of the Large Enterprise Examination and Crimin... More