Sho Matsukizono Head of Transfer Pricing - Tax, Partner

Sho joined Mazars in 2023 as Head of Transfer Pricing in Japan.

As a transfer pricing specialist, Sho has been advising both foreign and Japanese multinationals with various transfer pricing projects related to transfer pricing planning, tax audit, Advance Pricing Arrangement (APA), Mutual Agreement Procedure (MAP), BEPS transfer pricing documentation, Post-Merger Integration (PMI) advisory, due diligence, valuation of intangible assets, establishment of group tax governance regime, etc. He assists clients in their global business expansion, and has expertise in a wide range of industries including industrials, electronics, automotive, healthcare, consumer, apparel, entertainment, IT, financial services, etc.

Before joining Mazars, Sho was serving as M&A advisor and transfer pricing consultant for a foreign investment bank and the Big Four tax firm.

Raised in Paris, Sho spent 15 years in France and U.S. He has strength is cross-border project management built on his tax expertise and communication skill.

Sho holds BS degree in Political Science and Economics at Waseda University and MBA at Rice University.

Sector experience

• Manufacturing
• Wholesale
• Retail
• Service
• Financial Services

Expertise areas

• Transfer pricing services (design of transfer pricing (TP) policy, TP risk analysis, TP plannings, Advance Pricing Arrangement (APA), Mutual Agreement Procedure, BEPS documentation, audit defense, due diligence, etc.)
• Global tax planning (establishment of global tax governance structure through TP plannings such as Post-Merger Integration (PMI), group/business reorganizations, optimization of effective tax rate, operational TP, fund repatriation strategy, Intellectual Property (IP) management, etc.)
• Tax audit defense
• Valuation of intangible assets

Language capabilities include Japanese, French and English