Photo, Akihiko Tsuda

Akihiko Tsuda

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


Aki Tsuda is a partner* in the Firm's Tax & Transfer Pricing (TP) group in Tokyo.

Prior to joining Baker McKenzie in 2020, he provided TP services to multinational enterprises while working at Big Four accounting firms in Japan and the US.

He is fluent in English.

(*Partner as used above means a senior professional responsible for case management but does not imply a profit-sharing relationship with the partnership.)

Practice Focus

Aki's practice focuses on bilateral and unilateral APA, BEPS-related documentation, design and implementation of TP policy, contemporaneous TP study (i.e., 6662), valuation, restructuring of global supply chains, tax audit support and year-end TP analysis (i.e., Fin 48).

Representative Legal Matters

  • Engaged in a number of Japan-US bilateral APAs involving companies in a variety of industries, including automotive, transportation equipment, electronics, pharmaceuticals, precision and medical equipment, IT, sporting goods, office utilities and energy.
  • Designed and supported the implementation of TP policies for multiple major manufacturing companies, including negotiations with foreign related-entities.
  • Engaged in many IP valuations.
  • Prepared TP analysis and documentation for year-end audit purposes.


  • Southwestern University School of Law (JD) (2016)
  • Waseda University Graduate School of Law (2003)
  • Chuo University (1993)


  • English
  • Japanese