We are pleased to announce that Mr. Hitoshi Kobayashi, a graduate of Graduate School of Commerce, has been awarded the 31st Tax Museum Encouragement Award from the Tax Museum, a Public Interest Incorporated Foundation.
Received the 31st Tax Museum Encouragement Award from the Tax Museum, a public interest foundation
Hitoshi Kobayashi (Graduate Graduate School of Commerce)
Title: "A Study on Cost Sharing Agreements in Transfer Pricing Taxation: Focusing on Intangible Asset Transactions"
In order to support tax law studies and academic research closely related to tax law, the Tax Museum selects the Tax Museum Award every year for outstanding books and papers on tax law, etc. The Tax Museum Award is an award given to books and papers on tax law, etc., and the Tax Museum Encouragement Award is given to papers written by graduate students.
*Details about the Tax Museum Awards can be found on the Tax Museum's official website.
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Comment from the winner
I am truly honored to receive the prestigious Tax Museum Encouragement Award.
In this paper, when considering the issue of transfer pricing taxation on intangible assets that accompanies the globalization of corporate activities, I focused on cost sharing agreements, which can avoid this issue in advance without assuming ownership of rights, and examined the possibility of their application. As someone involved in practice, I am very pleased that my research into tax law based on corporate practice has been recognized.
Although I was conscious of the connection to practice from the stage of deciding on the topic, completing it as a research paper was more difficult than I had imagined. In that situation, Professor Tai gave me timely and accurate guidance, and I would like to express my gratitude once again for accompanying me, a slow writer, over the New Year holidays.
I would also like to express my sincere gratitude to everyone in Tai's seminar, who worked hard with us despite having few opportunities to meet in person due to the COVID-19 pandemic, my classmates in the Small and Medium Enterprise Consultant Training Program with whom I shared the good times and the bad, and the staff at the secretariat.Thank you very much everyone.
Comments from supervisors
Mr. Hitoshi Kobayashi, a graduate of Graduate School of Commerce, received the 31st Tax Museum Encouragement Award from the Public Interest Incorporated Foundation Tax Museum. His presentation was titled "Research on Cost Sharing Agreements in Transfer Pricing Taxation: Focusing on Intangible Asset Transactions."
Kobayashi used his practical work experience to conduct research and write his thesis. Since there are few research papers in Japan on cost sharing agreements in transfer pricing taxation, he has referred to the OECD Transfer Pricing Guidelines and US court cases for his research. There has been a growing awareness of the importance of cost sharing agreements in practice in recent years, and as this is an area that requires further research in the future, the contribution of this thesis is likely to be of great value.
While the number of submissions for the Tax Museum Award has increased in recent years, the judging criteria have become stricter due to the influence of copywriters, etc. Under these circumstances, we are pleased that Chiba University of Commerce Graduate School 's thesis winning the award proves the high level of our graduate school.
If you have created a good piece of work, why not submit it for the Tax Museum Award, whether you are self-nominated or nominated by someone else?
(Supervisor: Professor Yoshio Tai)
Left: Professor Yoshio Tai (supervisor) Right: Mr. Hitoshi Kobayashi
Previous years' Tax Museum Award and Tax Museum Encouragement Award winners
- 30th Annual 2021
Title: "A consideration of the timing of profit and loss attribution under the Corporation Tax Law regarding subsequent events: Focusing on an analysis of court cases including the issue of determining the liability to return interest in excess of the limit"
Mr. Hirohiko Shinbayashi, Graduate of Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Koichi Saito) - 2019 28th
Title: "Various tax issues related to virtual currencies and tokens: Focusing on the current state of income taxation and future taxation"
Mr. Fuyuki Shibata, Graduate of Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Koichi Saito) - 2018 27th
Title: "Issues with the Special Taxation Measures Act as an Investment Promotion Tax System: An Examination of Special Taxation Measures and the Patent Box Tax System as Investment Incentives"
Graduate School of Economics (SME Management Consultant Training Course) Graduate, Atsushi Arakaki (Supervisor: Professor Yoshio Tai) - 2015 24th
Title: "Securing International Taxing Rights and Addressing Base Erosion: Reconsidering the Principles of International Division on International Double Non-taxation"
Mr. Kuniyasu Inami Visiting Professor Graduate School of Accounting & Finance, MBA Program - 2014 23rd
Title: "A Study on the Tax System for Donations - Focusing on the "Institutionalization of Year-End Adjustment for Donation Deductions""
Daisuke Uemura, Graduate of Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Tsuneo Arima)
Title: "A Study on Consumption Tax: Tax Exemption for Social Insurance Medical Treatment and the So-called 'Loss Tax'"
Mr. Shunsuke Kanehara, Graduate of Graduate School of Accounting & Finance, MBA Program (Supervisor: Professor Satoko Kimoto) - 2012 21st
Title: "Countermeasures against tax avoidance in corporate tax trusts: Countermeasures against tax avoidance through multi-layered schemes using foreign trusts"
Mr. Yasuhiro Fushimoto, Graduate Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Susumu Honjo) - 2011 20th
Title: "Residency rules for inheritance tax"
Mr. Hideto Negishi, Graduate Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Susumu Honjo)