Tax planning that expands your business and life options
Before a Transaction Begins,
Designing Structures with Tax in Mind.
Establishing a company, expanding overseas, or reorganizing businesses and assets: even with the same goal, tax consequences vary depending on who acts, where, and through what structure.
The strength of Yanagisawa International Tax & Accounting isStructuring and Restructuring. Our principal and tax accountant, Kenji Yanagisawa, listens to your goals and helps design business and transaction structures from both tax and financial perspectives.
Structuring
Design the Structure for What Comes Next
We map individuals and companies, domestic and overseas operations, share ownership, contracts, and cash flows, then consider the structure and sequence suited to your goals.
Restructuring
Redesigning Existing Structures
We review existing relationships between companies, businesses, and assets, considering the tax costs and procedures of restructuring as well as future operations.
Tax Planning, Tax Avoidance, and Tax Evasion.
How Should We Think about the Space between Black and White?
Actions to reduce tax burdens are generally considered in three categories: tax saving, tax avoidance, and tax evasion. This diagram illustrates the differences as a gradient from white to black.
White: Lawful Tax SavingsLegally reducing the tax burden through regimes and options contemplated by law.
Gray area: Tax avoidanceEven if formal requirements are met, questions may arise about legislative intent and anti-avoidance provisions.
Black: Tax EvasionEscaping tax through fraudulent conduct such as hiding sales or falsifying facts.
The colors are a conceptual aid, not a numerical measure of legality or the likelihood of challenge. Tax avoidance and tax evasion are different concepts. Specific judgments require examination of the facts and applicable law.
We do not participate in concealing facts or falsifying past transactions. Future transactions, however, offer choices of structure.Designing arrangements after considering the actual business purpose and substance and verifying the tax basis, effects, and risksis tax planning.
Reference:National Tax Agency, Tax College Research Journal: “A Study on the Denial of Tax Avoidance Arrangements”(research paper)
When the structure changes, the tax consequences change.
Three Examples.
This is not limited to cross-border transactions. Japanese tax treatment of dividends and share transfers, and combinations of asset ownership and financing, also significantly affect tax outcomes.
01 Google's International Tax Strategy
“Double Irish” and “Dutch Sandwich” sound like dishes, but they refer to international tax avoidance structures combining Irish and Dutch companies. They attracted attention as part of Google's tax strategy.
Read More →02 SoftBank's Arm Reorganization
On July 9, 2024, the Ministry of Finance published its Explanation of the FY2024 Tax Reforms. It included revisions to the special rules reducing the tax book value of subsidiary shares following receipt of dividends from the subsidiary.
Read More →03 Leveraged leasing
Companies with substantial profits may be offered investments in aircraft, ship, or other leasing businesses. The ability to deduct a certain proportion of the investment early may seem attractive as a way to reduce corporate tax.
Read More →The above are research and explanatory examples for understanding structures, not assignments handled by our office. Each article also explains subsequent legal changes. They do not imply that the historical structures remain available today.
Could Your Business Also
Benefit from a Review of Its Structure?
What these examples share is that tax was considered from the design stage, rather than only after the transaction. Who holds the assets, which entity operates the business, and in what order transactions occur are all part of that design.
A new business, an acquisition or sale, group restructuring, or overseas expansion: starting with your goals, we can explore the available options and how their tax consequences differ.
The Past Cannot Be Changed.
We Can Consider Future Options Together.
Consult us before signing contracts, transferring money, establishing companies, or moving assets. We first clarify your objectives and circumstances, then identify issues to check and propose next steps. We consider implementation and maintenance costs and operational burdens as well as tax amounts.
Initial Consultation and Inquiries
Initial Consultation: JPY 55,000 per Hour
Our principal and tax accountant, Kenji Yanagisawa, will meet with you online or in person.
Where consumption tax applies, it is included in the displayed price. Where export exemption applies, the full displayed amount is the consultation fee. Your total payment remains the same in either case.
If detailed research, structuring, or implementation support is needed, we explain the scope and fees after the initial consultation.