Luke Tanner

Luke focuses on tax and transfer pricing for Japanese and foreign corporations and assists in planning, implementing and supporting his clients' corporate tax positions. He is experienced in complex international tax matters and cross-border M&A transactions, including due diligence, reviewing financial models and legal agreements, financing and structuring, tax-effective profit repatriation and exit strategies. Luke is also experienced in transfer pricing matters, including pricing policies involving profit splits and intellectual property transactions, permanent establishment profit attribution and intra-group financing. He has a track record of tax controversy support, including assistance with tax and transfer pricing audits and obtaining bilateral APA and MAP agreements.

• Advised clients in a range of industries, including life sciences, technology, media, telecom and financial services, concerning international tax issues arising from their business operations and transactions.
• Assisted clients in the application for, and conclusion of, several bilateral APA and MAP agreements, including Japan, Australia, the US, UK and European countries.
• Supported clients in the pharmaceutical, financial services and technology industries with respect to tax and transfer pricing audits of their operations.
• Advised clients on structuring and intercompany pricing of their business when starting operations, restructuring mature operations and terminating operations.

• American Chamber of Commerce in Japan - Tax Committee Member
• Australia and New Zealand Chamber of Commerce in Japan - Member