Hideyuki Yamamoto is a member of the Firm’s Tax and Transfer Pricing Practice Group in Tokyo, and previously worked in the Firm’s Washington office. He advises mainly on dispute related matters, including tax litigation. Prior to joining Baker McKenzie, Mr. Yamamoto was engaged for several years as a CPA at one of Japan’s largest accounting firms. Mr. Yamamoto successively held various positions at the Japan Federation of Bar Associations, including member of the Taxation Committee, chairman of the Tax Procedure and Tax Dispute Division, and vice chairman of the project team to reform the Act on General Rules for National Tax. He also served as chairman of the Tokyo Bar Association Tax Committee.
Representative Legal Matters
- Acted as lead counsel for Adobe Systems in an action to seek revocation of transfer pricing taxation (entire reassessment revoked: Tokyo High Court decision on 30 October 2008 (final)).
- Acted for a foreign corporation in an action to seek revocation of taxation on derivatives transactions (reassessment of approx. 11 billion JPY reversed: Tokyo District Court decision on December 7, 2012, Tokyo High Court decision on 24 October 2013 (final)).
- Represented a Japanese electronic component company in an administrative appeal to seek revocation of transfer pricing taxation (most of the reassessment reversed).
- Acted for a chemical make in a review application to seek revocation of transfer price taxation (part of the reassessment reversed).
- Acted for a Japanese corporation in an appeal to National Tax Tribunal to seek revocation of entire tax imposed on the donation made to a Southeast Asian public corporation in relation to the sale of a system based on international bidding (revoked in its entirety).
- Acted for a Japanese corporation in an administrative appeal to seek revocation of entire tax imposed on the donation made in relation to the acquisition of resource development interests in Southeast Asia (revoked in its entirety).
- Represented a client in an action seeking cancellation of a notice disposition on the ground of no cause against the request for correction seeking application of special deduction on income from an assignment of residential property (cancelled in its entirety: Tokyo High Court decision on 15 July 2010 (final)).
Professional Associations and Memberships
- Japanese Institute of Certified Public Accountants
- Tokyo Bar Association
- Tokyo Certified Public Tax Accountants Association
- Japan Tax Litigation Society
- Japan Tax Jurisprudence Association
- Licensed Tax Attorney (Zeirishi)~Japan (1995)
- Japan (1994)
- University of Pennsylvania Law School (LL.M.) (1998)
- Kyoto University (Bachelor of Economics) (1981)
- Washington, DC
"Reasonable Grounds in the Additional Tax for Deficient Returns," Administration and Citizen's Right, Houritsu Bunka-sha, December 2011
“A case where the calculation method of the disposition authority was not deemed as ‘a same method as a method equivalent to the Resale Price Method’ - the Adobe case,” Practical Exposition of Tax Cases, Shinzansha Publisher, August 2011
Author, “Adopting ‘Text-Based Interpretation’ in Tax Litigation: Points in the Supreme Court Decision on Bailiwick of Guernsey Case (Tax Haven Countermeasure Taxation),” Keiri Joho, Chuokeizai-sha, 10 March 2010
Author, “Secret Comparables-based Transfer Pricing Taxation and Self-Assessment Taxation,” Sozei Sosho No.3, Sozeisosho Gakkai, February 2010
Author, “Comparability in Transfer Pricing Taxation,” Jiyu to Seigi, Japan Federation of Bar Associations, February 2010