Partner Ryosuke Kono

Osaka Bar Association, Japan Federation of Bar Associations (2001)
New York State Bar Association (2007)

Location ： Osaka Office

Practice Areas

      Professional Summary

      Ryosuke Kono is a partner at Oh-Ebashi LPC & Partners. He represents clients in a number of complex tax litigation and administrative controversies. He also advises on tax matters in various types of domestic and cross-border transactions.

      His practice covers a wide range of tax issues, including transfer pricing, anti-tax haven rules (CFC rules), withholding rules, depreciation, permanent establishment (PE), customs duties as well as issues relating to cross-border restructuring, mergers and acquisitions and joint venture.

      He previously served as a Review Officer (International Examination) for the Review Division (Large Enterprise Examination) of the Osaka Regional Taxation Bureau, where he handled a broad range of complex tax issues.

      Education & Professional Experience

      2009-2011
      Osaka Regional Tax Bureau, as a fixed term officer

      2006-2007
      Weil, Gotshal & Manges LLP, New York

      2006
      New York University (LL.M.)

      2000
      Kyoto University (LL.B.)

      Activities

      2012 - present
      Vice-chairman, International Committee of Osaka Bar Association

      2012 - present
      Member, Japan Tax Jurisprudence Association

      2009-2012
      Visiting Researcher, Center for Law and Policy Studies Graduate School of Law Kyoto University

      Member, Japan Association of Arbitrators

      Publications Archives

      2018.07.20
      A Study of Practical Measures from a Taxation Requirement Perspective to Address Differences in Opinion with Tax Authorities - From Tax Investigation to Tax Litigation
      2018.06.22
      The Use of Tax Haven Companies as Investment Vehicles under the New CFC Rule of Japan
      2017.06
      Lawyers Guide - Labor/Tax edition A Supplementary Volume to Business Law Journal No.113 (August 2017)
      2016.09
      Web Commentary on TPP "3　Rules of Origin and Origin Procedures"
      2016.08
      Development of the Theory of Ultimate Facts in Tax Litigation
      2016.08
      Challenges of the Theory of Ultimate Facts in Tax Litigation ─ Perspective of a Former Fixed-Term Official of the Review Division, the Regional Tax Bureau
      2016.03
      Details of the Amendments to the Transfer Pricing Taxation based on the Outline of the 2016 Tax Reform Proposals, and the Practical Effects Thereof
      2014.03
      Key Considerations in Interpreting Tax Law for Cross-Border Debt-for-Equity Swap
      2013.11
      Study on the Process for Finding Facts Constituting the Taxation Requirements under the Transfer Pricing Taxation System
      2013.11
      Practical Guide to the Act on Special Measures for Consumption Tax Shifting
      2013.09
      Practical Considerations in Applying Transfer Pricing Taxation to Intangibles Transactions
      2004.03.03
      Theory and Practice with respect to New Corporate Reorganization Act, as well as relevant Forms, for Practices of Receiver in Bankruptcy

      Seminars/Lectures Archives

      2024.06.21
      【Online Seminar】 Seminar on Legal Practices for Companies Expanding Their Business Abroad (13): Fundamental Taxation Risks in Expanding Business Abroad
      2022.04.06
      【Onilne Seminar】New Series of International Legal Practice Seminars (8): International Taxation - Key Points on Resolving and Avoiding Disputes
      2021.06.15 ～2021.06.19
      IPBA VIRTUAL CONFERENCE - Innovative Resilience in an Altered Legal Landscape
      2018.02.28
      Recommendation of Tax Litigation - Lessons Learned from a Case where the Taxpayer Won
      2017.07.21
      Special Commemorative Seminar to Celebrate the 20th Anniversary of the Retrocession of Hong Kong - Practical Points in Using Hong Kong as a Business Hub (Osaka)
      2017.04.21
      Special Commemorative Seminar to Celebrate the 20th Anniversary of the Retrocession of Hong Kong - Practical Points in Using Hong Kong as a Business Hub (Tokyo)
      2016.12
      Practical Points on Overseas M&A that Accounting and Tax Staff Should Know
      2015.06
      Examination of Recent Significant Court Decisions on International Taxation
      2014.07
      Material Points on Tax Practices that Legal Staff Need to Know
      2014.04
      Seminar on Tax Issues for Legal Department Members
      2014.01
      Practical Measures Related to the Amendment of the Consumption Tax Act - Key Considerations for Avoiding Trouble
      2013.04
      Transfer Pricing & Customs Duty
      2012.10
      Major Issues Related to Transfer Pricing Taxation - With Particular Focus on Transfer Pricing Risks in Intangible Transactions
      2012.05
      Introduction to International Taxation

      Awards

      Awarded “LAWYER OF THE YEAR 2022 in Tax Law” by Best Lawyers
      Awarded “LAWYER OF THE YEAR 2024 in Tax Law” by Best Lawyers

      Languages

      Japanese and English

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