Edwin Whatley

Edwin T. Whatley

Baker & McKenzie (Gaikokuho Joint Enterprise)


Edwin Whatley is a partner of the Firm's Tax Practice Group in Tokyo and is highly experienced in both US and Japanese tax law. He is recognized as a leader in his field by the Asia Pacific Legal 500, ITR World Tax and Chambers Asia. Edwin has authored numerous articles on US and Japanese tax and regularly speaks on tax matters at international conferences and seminars. He is actively involved in pro bono work, including assistance on various matters to the California, Georgia and Tokyo Bar Association. Prior to joining the Tokyo office, he worked in the Firm's San Francisco practice.

Practice Focus

Edwin focuses on international taxation, corporate and international tax planning, transfer pricing and tax controversies for Japanese and foreign corporations. He also works with clients on reorganizations and acquisitions in Japan. He advises on transfer pricing analysis and controversies, and helps Japanese multinationals on foreign tax issues. He is seasoned in unilateral and bilateral transfer pricing matters involving Japan, the US and other countries. He also handles tax structuring, preparation of documentation, and Japanese tax rulings to reduce or eliminate withholding tax on transactions in software and other intangibles, as well as Japanese consumption tax and customs.

Representative Legal Matters

  • Worked with a range of US and international corporate clients, including numerous high-tech companies.

  • Advised US companies and worked closely with Japanese lawyers on the commercial, corporate, intellectual property and tax law aspects of Japanese operations.

  • Prepared and reviewed distribution, licensing, OEM and joint venture agreements.

  • Acted for US clients in relation to corporate tax planning for Japanese operations and tax planning for US expatriates stationed in Japan.

  • Represented US clients in administrative proceedings and litigation in tax and intellectual property matters.

  • Represented and assisted Japanese companies with respect to their US operations involving US and multinational tax planning, US acquisitions, US tax controversies (especially transfer pricing matters) and US litigation.

Professional Honors

  • Tax - Band 1, Chambers Asia (2011 - 2020)
  • International Trade - Band 1, Chambers Asia (2011 - 2020)
  • Tax: Foreign - Leading Lawyer, Legal 500 (2010 - 2020)
  • Leading global tax lawyers, Asia Pacific Legal 500, ITR World Tax and Chambers Asia (2020)

Professional Associations and Memberships

  • California Bar Association - Member
  • Georgia Bar Association - Member
  • Tokyo Bar Association - Member
  • International Fiscal Association - Member 
  • American Chamber of Commerce in Japan's tax committee - Co-Chair

Corporate Responsibility

Edwin provides pro bono assistance on various matters through his membership of the California, Georgia and Tokyo Bar Associations, and takes part in charitable activities in his work with various non-profit organizations. He also devotes substantial time on a voluntary basis to the International Fiscal Association and the Tax Committee of the American Chamber of Commerce in Japan.


  • Foreign Registered Lawyer (gaikokuho jimu bengoshi)~Japan (1996)
  • Georgia~United States (1992)
  • California~United States (1990)


  • Stanford University (JD) (1990)
  • Harvard University (AB) (1981)


  • English
  • Japanese


  • Co-author, "Japan, BNA Global Tax Guide", BNA, London, 2009 (and subsequent updates)


  • Co-author, "Japan’s Corporate Tax Measures in Response to Covid-19", Daily Tax Report: International, Bloomberg Tax, October 2020

  • Co-author, "Japan", Handling Tax Disputes In Asia Pacific 2020, Baker McKenzie, October 2020

  • Co-author, "Kon'nichiwa, Nihon! Baker McKenzie breaks down the Key Legislation of the Island Nation", Hubbis, September 2020

  • Co-author, "What Japan's 2019 Reform Means For Mulnaonals", Tax Notes International, Tax Notes, November 2019