Koichiro Yoshimura

Practice Areas

Taxation / Tax Controversy / Tax Advice and Planning.

Koichiro Yoshimura is a tax partner at Nagashima Ohno & Tsunematsu. He has extensive experience in the field of taxation, covering both tax planning and tax disputes (including tax audits). His particular strength lies in the area of international taxation and providing advice to foreign clients, based on his experience on international tax policy matters at international organizations.

Career

United Nations, Department of Economic and Social Affairs, Financing for Development Office, International Tax Cooperation Unit (2014-2015);

Organisation for Economic Co-operation and Development, Centre for Tax Policy and Administration, International Co-operation and Tax Administration Division (2015-2017);

Partner of Nagashima Ohno & Tsunematsu since 2020

Professional Memberships

Bar of Japan (2007);

Bar of the State of New York (2013);

Member of the Board of the International Fiscal Association Japan branch

Publications

Clarifying the Meaning of “Beneficial Owner” in Tax Treaties, 72 Tax Notes Int’l 761 (2013);

IFA Branch Report for Japan for 2023 Congress;

Chambers Global Practice Guides - Tax Controversy - Japan (2024);

Chambers Global Practice Guides - Alternative Funds - Japan (2024);

Chambers Global Practice Guides - Project Finance - Japan (2024)

Work Highlights

A case in which the taxation of withholding income tax related to interest payments on bonds issued to foreign banks was held to be illegal on the ground of an error in identifying the taxable entity to which the income should be attributed (Tokyo District Court, Judgement on February 1, 2022 (final and binding));

A case in which a reassessment issued under the Japanese CFC regime was held to be illegal, by accepting the taxpayer-client’s argument that a legal arrangement involving a Dutch entity, Stichting, constitutes a “trust” for Japanese tax purposes (National Tax Tribunal, Decision on March 14, 2024 (final and binding))

Education