Attorneys
Attorneys
Kohei Kajiwara
Partner, Attorney-at-Law and Certified Public Accountant
Kohei Kajiwara provides comprehensive legal and tax advice primarily to startups, listed companies, small and medium-sized enterprises, foreign companies, and audit firms. He is particularly focused on supporting the execution of the following types of transactions:
| ● | Fundraising and investments involving shares and stock acquisition rights |
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| ● | Design and implementation of incentive compensation plans such as stock options, restricted stock, restricted stock units, and performance share units |
| ● | Structuring to facilitate innovative initiatives by startups and other entities, as well as launching new businesses |
| ● | M&A transactions and intra-group reorganizations involving domestic and international companies, and investments and market entry into Japan by foreign corporate groups |
In addition to legal and tax expertise, he leverages his accounting background to handle the following matters:
| ● | Support for the planning and execution of capital transactions including share buybacks and capital reductions |
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| ● | Support for responses to tax audits, administrative appeals, and tax litigation, as well as requests for advance rulings from relevant tax authorities |
| ● | Advice to tax accountant firms regarding tax accountant liability issues |
| ● | Legal advice to listed and other companies and audit firms regarding corporate accounting and auditing matters |
| ● | Legal advice to audit firms regarding compliance with The Japanese Institute of Certified Public Accountants’ self-regulatory framework |
With all of his knowledge and expertise, he is committed to supporting his clients in finding the best solutions and achieving their goals.
Career
| ● | 2005 | Oita Uenogaoka High School |
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| ● | 2010 | The University of Tokyo (Bachelor of Economics) |
| ● | 2013 | The University of Tokyo School of Law (J.D.) |
| ● | 2014 | Admitted in Japan (Dai-ichi Tokyo Bar Association) |
| ● | 2015 – 2025 |
Anderson Mori & Tomotsune |
| ● | 2020 | Graduate study, Vienna University of Economics and Business (Wirtschaftsuniversität Wien) (LL.M. in International Tax Law), Austria |
| ● | 2021 – 2023 |
Clayton Utz, Brisbane, Australia |
| ● | 2023 | Registered as a Certified Public Accountant (Japan) |
| ● | 2024 – | Lecturer (Tax Case Law Studies), Center for Professional Legal Education and Research, Waseda University |
| ● | 2025 – | Y Cube Law Office |
Legal Awards
Best Lawyers: Ones to Watch in Japan – Tax Law (2023, 2024, 2025 and 2026)
Selected Publications
| ● | Eiichiro Nakatani & Kohei Kajiwara, “Interpreting the Supreme Court Decision on Japan’s CFC Rules: Taxation Based on a Literal Interpretation of Statutory Provisions and Triggered by Satisfaction of Objective Requirements” (Kinyu Zaisei Jijo Weekly, February 13, 2024) February 2024 |
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| ● | Kohei Kajiwara, “Characteristics and Issues of Japan’s Advance Ruling System: A Comparative Analysis with Australia’s Private Rulings” (T&Amaster Weekly, No. 999, October 16, 2023) October 2023 |
| ● | Kohei Kajiwara, “[Tax Case Update] Reference Time for Determining Shareholding with Consideration of Claim Rights Under the CFC Rules— Tokyo District Court Judgment dated March 16, 2021” (Jurist, No. 1568, March 2022) March 2022 |
Articles and Seminars
| ● | The Inward Investment and International Taxation Review (Japan Chapter) – 7th to 9th, 11th Editions (Co-author) 2017 – 2019, 2021 |
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| ● | Lecture “Taxation of Financial Transactions” at The University of Tokyo School of Law (Guest speaker) November 2020 |
| ● | The coverage of hybrid entities under the MLI: Interpretation of the provisions and analysis of opting countries and consequent changes to tax treaties (Hybrid Entities in Tax Treaty Law) September 2020 |
| ● | Doing Business In... 2019 - Law & Practice (Chambers and Partners) (Co-author) July 2019 |
| ● | Relationship Between Tax Treaties and Domestic Tax Law (T&Amaster Weekly, No. 777) (Co-author) March 2019 |
| ● | JAPAN: CFC Rules (Tax Management International Forum Vol. 39, Issue 4) (Co-author) December 2018 |
| ● | APAN: Sharing Economy (Tax Management International Forum Vol. 39, Issue 3) (Co-author) August 2018 |
| ● | The Supreme Court’s Logic in the DENSO Case: Business Test Under the CFC Rules (T&Amaster Weekly, No. 719) (Co-author) December 2017 |
| ● | Getting the Deal Through - Tax Controversy 2018 (Japan Chapter) (Co-author) October 2017 |
| ● | We Will Be Landing Soon: A Multinational Survey of the Treatment of Income and Gains of Individuals Who Change Residence (Japan Chapter) (Journal of International Taxation) (Co-author) April 2017 |
| ● | Revisions to the Tax Treatment of Executive Compensation Under the 2016 Tax Reform (The Lawyers Monthly, March 2016) (Co-author) March 2016 |