Yoshihiro Masui

The University of Tokyo, Graduate Schools for Law and Politics

Professor

Hongo 7-3-1

Bunkyo

Tokyo, Tokyo 113-0033

Japan

http://www.masui.j.u-tokyo.ac.jp

SCHOLARLY PAPERS

12

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Scholarly Papers (12)

1.

Interest Deduction, Corporate Groups and Tax Jurisdictions: A Hitchhiker's Guide to an Aspect of the BEPS Project

Asia-Pacific Tax Bulletin, March/April 2014, 103-107
Number of pages: 5 Posted: 01 Sep 2014 Last Revised: 31 May 2015
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 1,776 (8,593)

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MNE, Taxation, Profit shifting, Thin capitalization, Hybrid mismatch arrangements

2.

Taxation of Foreign Subsidiaries: Japan's Tax Reform 2009/10

Bulletin for International Taxation, Vol. 64, No. 4, pp. 242-248, April 2010
Number of pages: 7 Posted: 11 May 2011
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 210 (142,562)

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International taxation, Foreign tax credit, CFC legislation

3.

International Fiscal Association 2004 Vienna Congress, General Report: Group Taxation

Cahier de droit fiscal international, Volume 89b, pp. 21-67, 2004
Number of pages: 48 Posted: 12 May 2012
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 168 (173,808)

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group taxation, corporate groups, tax planning

4.

Introduction of the Authorised OECD Approach into Japanese Domestic Law

Bulletin for International Taxation, Vol. 69, No. 9, Pages 510-519.
Number of pages: 10 Posted: 10 Sep 2015
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 120 (228,037)

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international taxation, tax treaty, permanent establishment, AOA

5.

The Responsibility of Judges in Interpreting Tax Legislation: Japan's Experience

Osgoode Hall Law Journal 52.2 (2015) : 491-512
Number of pages: 23 Posted: 14 Jul 2015 Last Revised: 10 Sep 2015
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 108 (246,097)

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Statutory interpretation, tax-lawmaking

6.

Interaction between Tax Treaties and Domestic Law in Japan – The Role of a Coordinating Statute

New York University ed., ITP@20, 335-347 (2016)
Number of pages: 14 Posted: 16 Dec 2016
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 98 (262,993)

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tax treaty

7.

Taxation and Development in Japan

University of Tokyo Journal of Law and Politics, Vol.13, Summer 2015, Pages 55-60.
Number of pages: 6 Posted: 13 Sep 2015
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 94 (270,187)

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harmful tax competition, tax incentives, BEPS

8.

Transfer Pricing and Customs Duties

50 Bulletin for International Fiscal Documentation 315
Number of pages: 6 Posted: 14 Jul 2015 Last Revised: 29 Jul 2015
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 91 (275,827)

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transfer pricing, customs valuation, international taxation

9.

Overhaul of the Japan-US Tax Treaty in 2003

The Japanese Annual of International Law, No. 49, pp. 55-70, 2006
Number of pages: 17 Posted: 14 Jun 2011
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 89 (279,711)

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tax treaty, source-based taxation, limitation on benefits, treaty shopping, hybrid entities

10.

The Influence of the 1954 Japan-United States Income Tax Treaty on the Development of Japan’s International Tax Policy

Bulletin for International Taxation, Vol. 66, No. 4/5, 2012
Number of pages: 9 Posted: 27 Feb 2012 Last Revised: 11 May 2012
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 81 (296,365)

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tax treaty, international taxation, legal transplant

11.

Treaty Arbitration from a Japanese Perspective

Bulletin for International Fiscal Documentation, Vol. 58, No.1, pp.14-16, 2004
Number of pages: 3 Posted: 11 Jul 2011
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 60 (348,888)

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tax treaty, arbitration, Japanese Constitution

12.

Parliamentary Involvement in the Conclusion of Tax Treaties in Japan

Brian J. Arnold, ed., Tax Treaties After the BEPS Project: A Tribute to Jacques Sasseville (Toronto: Canadian Tax Foundation, 2018)
Number of pages: 14 Posted: 12 Sep 2018
Yoshihiro Masui
The University of Tokyo, Graduate Schools for Law and Politics
Downloads 25 (481,983)

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Tax treaty, Parliament, Constitution