Yohei Ueno

Yohei Ueno

Baker & McKenzie (Gaikokuho Joint Enterprise)


Yohei Ueno is an associate in the Tax / Transfer Pricing Practice Group at Baker McKenzie's Tokyo office. Prior to joining the Tokyo office's Tax Practice Group, Yohei was a member of its Corporate/M&A Practice Group for over five years. He advises both Japanese and international clients on a variety of tax and corporate matters, including transactional, controversy and international matters. Yohei also has experience working in the US as a secondee at Baker McKenzie's Washington DC office. He is a member of the Tokyo Bar Association, and is qualified to engage in Zeirishi (tax accountant) services under Article 51 of the Certified Public Tax Accountant Act.

Practice Focus

Yohei provides international tax advice on cross-border organizational restructuring and handles general tax matters, including tax litigation. He also has expertise in M&A and general corporate matters. Yohei further leverages the experience and network he built while a member of the Baker McKenzie Washington DC office's Tax Group to seamlessly provide US tax advice.

Representative Legal Matters

  • Advised Japanese listed companies on tax haven countermeasures, tax treaties and other related tax systems in connection with their foreign investments and reorganizations.
  • Provided tax advice related to a Japanese asset management and investment company's overseas alternative investments.
  • Provided tax advice related to the structuring of a Japanese listed company's group in light of the OECD / Pillar 2 international minimum tax regime.
  • Supported a Spanish company in its acquisition of a US company (acquisition of partnership interests) from a US tax law perspective.
  • Represented a Luxembourg entity in a lawsuit requesting a refund payment applying the reduced tax rate for dividends between parent and subsidiary companies under the Japan-Luxembourg tax treaty in a case in which mutual agreement was not reached (fully granted by a Tokyo District Court decision on February 17, 2023).
  • Provided legal advice from corporate and tax law perspectives on M&As, integration and organizational restructuring for domestic and international companies.

Professional Associations and Memberships

  • Tokyo Bar Association - Member


  • Japan (2015)


  • Georgetown University Law Center (LLM in Taxation with Certificate in International Taxation) (Merit Scholar) (2022)
  • Kobe University Graduate School of Law (JD) (2012)
  • Kansai University (LLB) (2010)


  • Japanese
  • English

Previous Offices

  • Washington, DC