TP CONSULTING SERVICES
History of transfer pricing
We began providing international taxation consulting services in response to needs to solve international tax issues. For more than 30 years since then, we have been providing services related to international tax affairs.
The application of transfer pricing taxation was first strengthened in the United States in the early 1980s, and the demand for transfer pricing consulting spread from that country. In the 1980s, there were already transfer pricing professionals at overseas (U.S.) transfer pricing consulting service firms. In Japan, however, dedicated professional staff had yet to be developed, partly because needs related to transfer pricing were still limited. Later in 1986, a basic law on transfer pricing came into force in Japan as well and demand for transfer pricing consulting gradually began to grow.
In the early 1990s, there were a few full-time transfer pricing consultants at Tohmatsu, but we did not yet have a dedicated team. However, the need to build a dedicated team in Japan increased with the rise in transfer pricing issues. As the first step for creating a team for transfer pricing consulting services in Japan, we dispatched one Tohmatsu staff member to the Washington, D.C. office to cooperate closely with people in the United States, which had an increasing number of cases of transfer pricing taxation targeting major Japanese manufacturers. The Tohmatsu staff member built a cooperative relationship with specialists from the U.S. office and acquired expertise in consulting before they returned to Tokyo in the spring of 1997. The transfer pricing service division was established as a formal organization in the autumn of the same year.
In the early days after the establishment, consulting services were mostly provided to Japanese subsidiaries of foreign companies that were facing transfer pricing problems. Demand for transfer pricing consulting later grew rapidly because both Japanese and foreign companies began to face tax inspections and the imposition of huge amounts of back taxes related to transfer pricing. At present, the transfer pricing service division has more than 100 members in total in Tokyo and Osaka.