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Yukiko Komori

Yukiko Komori

Partner
Baker & McKenzie (Gaikokuho Joint Enterprise)
Not admitted to practice law in this jurisdiction

Biography

Yukiko Komori is a member of the Firm's Tax & Transfer Pricing Practice Group in Tokyo with over 30 years’ experience in transfer pricing. She works closely with tax authorities and overseas stakeholders, providing multinational companies across a variety of industries and jurisdictions with tailored, practical solutions.
Yukiko regularly speaks at seminars and publishes articles and books both in Japan and overseas on international tax matters. She has also participated in research projects led by the Japanese National Tax Agency and the Ministry of Economy, Trade and Industry.
Yukiko was listed in Euromoney’s Women in Business Law and has been nominated as a Women in Tax Leader and Notable Practitioner by ITR World Tax several times.

Practice Focus

Yukiko’s practice spans a broad range of transfer pricing matters, including advance pricing agreements (APAs), tax planning, audit defense and documentation. She is particularly skilled in helping clients navigate complex, high-stakes matters, including the introduction of innovative business models by global technology companies and business restructurings that significantly affect the profitability of Japanese entities. Combining creative thinking with a practical understanding of tax authority expectations, Yukiko has successfully secured favorable outcomes in both audits and APA negotiations. She has experience with a vast array of intercompany transactions, from traditional operating models to complex arrangements in rapidly evolving sectors such as technology and financial services.

Representative Legal Matters

  • Providing clients with economic analyses in a wide range of transfer pricing and international tax matters.
  •  Assisting leading multinational corporations with APA applications and negotiations for transactions related to digital services, data centers and innovative business models.
  • Supporting one of the world's largest privately held companies in the restructuring of its global manufacturing, distribution and sales operations, with a particular focus on Japanese transfer pricing considerations.
  • Assisted a major IT company in obtaining an APA following the conversion of its Japanese subsidiary from a service provider to a reseller.
  • Assisted a leading multinational corporation in obtaining an APA following a major business restructuring that converted its Japanese subsidiary from a full-fledged entity to a limited-risk entity.
  • Assisted an IT company in using an APA to mitigate permanent establishment risk associated with its data center operations.
  • Assisted an IT company in mitigating withholding tax risk through an APA by characterizing related-party transactions as software buy-sell transactions rather than licensing transactions.
  • Advised a leading global financial institution on transfer pricing issues arising from large-scale business restructuring.
  • Assisted a multinational enterprise engaged in complex cross-border transactions with related parties across multiple jurisdictions in significantly reducing its global transfer pricing risk through a single APA covering a broad range of transactions.

Education

  • Keio University (Bachelor's Degree Sociology) (1991)

Languages

  • Japanese
  • English

Publications, Presentations and Articles

Articles

  • Author, “Practical challenges in managing intellectual property and intangible assets from a transfer pricing perspective,” Patent, Japan Patent Attorneys Association, March 2026, Language: Japanese
  • Author, “Transfer pricing in cross-border business restructurings part 1 – fundamental transfer pricing concepts in restructurings,” International Taxation, Zeimu Kenkyukai, May 2022, Language: Japanese
  • Co-author, “Japan Advance Pricing Agreements in View of Covid-19 Disruptions,” Bloomberg Tax, April 2021, Language: English
  • Co-author, “New Tax Incentives for Companies with Certain Business Plans in Japan,” BNA, 3 December 2021, Language: English
  • Author, "Why do Japanese entities pay more in tax than foreign entities?" Tax planning - a game Japanese entities don't play, Nikkei Business Online, 8 September 2016, Language: Japanese
  • Author, "Japan entities left behind in the global tax war," Tax planning - a game Japanese entities don't play, Nikkei Business Online, 7 September 2016, Language: Japanese
  • Author, "Japan transfer pricing documentation guide," International Tax Review, July 2012, Language: English
  • Author, "Financial transactions questions - Japan," Transfer Pricing Forum, BNA International, October 2010
  • Author, "Developments in Japan" and "Transfer pricing disputes in Japan," Transfer Pricing International Journal, BNA International, March 2010, Language: English
  • Author, "Asian update: Japan," Tax Planning International Transfer Pricing, BNA International, May 2009, Language: English
Not admitted to practice law in this jurisdiction.

“Partner” as referred to in this material represents a senior-level professional who would be responsible for case management in each practice area, and does not mean profit-sharing members of the partnership.