Sessions
Attribution of profits to PEs: The Asia-Pacific transfer pricing perspective.
9:00 AM - 10:30 AM Thu
Practice Areas
Mr. Minami’s practice focuses on M&A transactions and tax law matters. Specifically, the latter includes transfer pricing, international merger and acquisitions, international reorganizations, anti-tax-haven (CFC) rules, withholding tax issues and other international and corporate tax issues, and, with respect to such matters, he negotiates with tax authorities and has acted as counsel in various tax disputes on behalf of major Japanese and foreign companies.
Affiliation:
Mr. Minami served as the Chair of the Asia-Pacific Region Committee of the International Fiscal Association (“IFA”) for 2016 - 2018 and serves as a member of the Practice Council of the International Tax Program at New York University School of Law. He also serves as a project member of the Study Group for the Implementation of Domestic Legislation regarding the Global Minimum Tax under Pillar Two, which was established by the Ministry of Economy, Trade and Industry from 2022.
Professional Experience:
Adjunct Lecturer of Law & Economics, The University of Tokyo (2010-present);
Visiting Professor of Tax Law, Graduate School of Law, Kobe University (2016-present); and
Adjunct Lecturer of Tax Law, Sophia Law School (2017-present).
Education:
University of Tokyo, (LL.B.) (1994), New York University School of Law (LL.M.), Corporate Law (2002) and Tax Law (2003)
Professional Memberships
Tokyo bar Association, Japan (1997)