Photo, Satoko Nakamura

Satoko Nakamura

Baker & McKenzie (Gaikokuho Joint Enterprise)


Satoko Nakamura is a member of the Firm's Tax & Transfer Pricing Group in Tokyo. She is proficient in the areas of international tax planning, as well as economic analysis. Ms. Nakamura has co-written the Guide to Practical International Tax Planning, and has contributed a number of articles to International Tax. Prior to joining the Firm, she worked for major Japanese audit and tax consulting companies.

Practice Focus

Ms. Nakamura provides insightful advice on a broad range of transfer pricing issues, such as designing global transfer pricing policy, and transfer pricing documentation. She has been involved in various advanced pricing arrangement cases covering Japan, the US, China, Korea, Australia and other countries. She has also assisted numerous multinational companies in resolving transfer pricing disputes at bilateral competent authority proceedings. Ms. Nakamura is part of a team that provides economic analysis and valuation for an array of transfer pricing and international tax matters.

Professional Associations and Memberships

  • Japanese Institute of Certified Public Accountants - Member
  • Japan Tax Accounting Association - Member


  • Licensed Tax Attorney (Zeirishi)~Japan (2006)


  • Osaka University (Economics) (1997)


  • English


“Tax Planning Strategy in an Economic Downturn and Possible Repatriation under the New Dividend Tax Exemption Rules – Use of the Dutch Cooperative,” International Tax, April 2009

“Implications of Business Restructuring and Supply Chain Management on International Taxation,” International Tax, October 2008


Co-author, Guide to Practical International Tax Planning, Chuokeizai-sha, November 2008