Tokyo

In 2016, we celebrated the 30th anniversary of our office in Tokyo. Already back in the 1980s Loyens & Loeff formed a specialised Japan Desk to meet the increasing demand for expertise in all tax and legal aspects relating to investments and trade between Japan and the Benelux.

Our Japan team, which is part of the Asia-Pacific (APAC) region team, assists both clients based in Japan with all types of outbound investments as also clients based abroad with respect to their inbound investments into Japan.

Loyens & Loeff’s Tokyo office and APAC team consist of tax lawyers, corporate lawyers and civil law notaries. They participate in Loyens & Loeff teams that focus on specific industries and sectors, such as energy, real estate, private equity, fund structuring, corporate finance and family office investments. This way clients have access to Loyens & Loeff's full-service tax and legal expertise with regard to Dutch, Belgian, Luxembourg and Swiss law. Team members are based in our Amsterdam and Luxembourg offices and frequently work from our Tokyo office.

In many cross-border transactions, investing through the Benelux brings several benefits. The Benelux tax climate is generally very attractive for Japanese investors because of:

• Low corporate income tax rate
• No withholding taxes on interest, royalties or fees for technical services
• No stamp duties, nor capital taxes
• Dividend tax, which is most often reduced (even to as little as 0%)
• Favourable special tax incentives (e.g. for R&D activities, Energy Investment Allowances, and a favourable tax regime for foreign skilled workers)
• Participation exemption: tax-exempt dividends and capital gains
• Advance tax rulings (ATRs) and pricing agreements (APAs), which can be obtained from the tax authorities
• VAT deferral on goods imported into the European Union
• Practical and proactive approach of the customs authorities
• Reduced compliance burden by filing consolidated tax returns, applying for functional currency
• Extensive tax treaty network (reduction of foreign withholding taxes) and bilateral investment treaty network

With respect to Japan’s outbound investments, our clients consist of Japan's major financial institutions, high-net-worth individuals, multinational corporations and private equity and real estate funds. We work closely with reputable Japanese law firms seeking our assistance in solving international tax and corporate law-related matters for their clients, and in establishing and restructuring overseas legal structures. 
 
With respect to inbound investments, our clients comprise both Dutch-based clients and international clients using the Netherlands (and Luxembourg) as a basis to enter the Japanese market or hold shares in Japanese companies. 
 
We advise Japanese clients on mergers, acquisitions, private equity transactions, international holding and financing entities, labour law, fund formation, investment management, real estate investments and tax planning for high-net-worth individuals. In many cross border transactions, benefits can be derived by investing through or from the Benelux (Belgium, the Netherlands and Luxembourg) or Switzerland. We would be happy to discuss these opportunities with you.