Transfer Pricing
Transfer pricing documentation, policy design, benchmarking, APAs, MAPs and controversy support across Europe, Japan and Asia-Pacific.
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Advisory,
across borders
and cultures.
SCS Collective supports Japanese multinationals across Europe and beyond, bringing together transfer pricing, international tax, business restructuring, transparency and Japan–Europe fluency. We are senior-led, practical, and directly accountable from the people doing the work.
20+ Countries
40+ Locations
1500+ Specialists
Amsterdam · Tokyo · Singapore
A Collective Of
Transfer pricing specialists,
international tax advisors,
controversy professionals,
indirect tax and customs experts,
and Japanese-speaking
cross-border practitioners
— working as one team around the client.
We combine technical depth,
local market knowledge
and an understanding of
how Japanese groups
make decisions across headquarters,
regional hubs and local operations.
01
What We Do
Careful work,
one client at a time.
We work with finance, tax and business leaders who want more than a report.
They want advisors who understand the business, stay close over time,
and can move between English and Japanese without losing the substance of the issue.
Our work is built for real decisions: board discussions, audits, restructurings,
filings, negotiations and conversations with tax authorities.
Craft
Senior-led from start to finish.
Your matter is handled directly by experienced specialists, with senior judgment involved from the first discussion to the final deliverable.
Culture
Multilingual where it matters.
We work across English and Japanese in a way that preserves nuance, whether in calls, reports, negotiations or explanations to headquarters.
Clarity
Advice built to be used.
Our advice is not written for the file alone.
It is shaped for the people who need to rely on it; in boardrooms, audits, negotiations and tax authority discussions.
Our Manifesto
Independent by design.
International tax and advisory work has become increasingly consolidated. Large firms have shaped the profession, trained many of its best people, and continue to do excellent work.
But scale can change the experience of advice. For many clients, the question is no longer simply whether the work can be done. It is who is actually doing it. Who understands the business. Who joins the call. Who writes the memo. Who stays when the matter becomes difficult.
SCS Collective exists for clients who want senior judgment, close attention and practical advice shaped around the way their business actually works.
— Independent. Senior-led. Built to stay close.
02
Services
Specialist advice for cross-border decisions.
International Tax
Cross-border structuring, Pillar Two, permanent establishment matters, holding company design and exit tax analysis.
→Tax Controversy
Audit defence, ruling requests, competent authority procedures and litigation support, coordinated with local counsel where required.
→Indirect Tax & Customs
VAT, customs valuation, supply-chain reviews, e-invoicing readiness.
→Business Restructurings
Operating-model and supply-chain redesign, principal and IP structures, post-acquisition integration, and the transfer pricing and exit-tax analysis that reorganisations require.
→Planning & Policy Design
Transfer pricing policy design, pricing models, intercompany agreements, and the substance and operational steps needed to make a policy work in practice.
→Transparency & Sustainability
Public country-by-country reporting, the EU tax transparency agenda, CBAM, and the growing overlap between sustainability reporting and tax — shaped into a position that can be explained with confidence.
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03
OUR OFFICES
04
The People
A helpful and
reliable partner.
Kenichi Shohtoku
Kenichi began his career at a major audit firm before being stationed in Kuala Lumpur, where he advised Japanese companies on market entry and ongoing operations. His work covered accounting, audit, tax, employment, legal, and government licensing matters. In 2002, he founded SCS-Invictus. As Group Managing Partner, he oversees group strategy, management, and expansion.
Akihiro Kitami
Akihiro began his career at a major Japanese logistics company. In 1996, he joined the accounting management team of its U.S. subsidiary and spent five years in New York. He later worked at mid-sized and major accounting firms in the United States before founding SCS Global Professionals, LLP, the U.S. member firm of SCS-Invictus, in 2006.
Alan Chalhoub
Alan joined SCS Invictus Group in 2026 after more than a decade at Deloitte, where he advised on transfer pricing and international tax matters across Tokyo, Amsterdam, and Bangalore. At Deloitte Netherlands, he also played a leading role in the Japanese Services Group, leading teams and cross-border initiatives for Japanese clients. He specializes in international tax planning, compliance, bilateral APAs, and MAPs for Japanese multinational groups, with a particular focus on Japan–Europe structures. He leads the SCS Collective’s European practice in Amsterdam.
The question is not whether large firms can do the work. Often, they can. The question is whether your matter receives the attention, judgment, and continuity it deserves.
The Invictus Brief
05
Global Reach
Independent by choice.
Global by design.
20+
Countries
40+
Locations
1500+
Specialists
1
Collective
06
Insights
Cross-border tax insights.
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hello@scscollective.eu
Out of the night that covers me,
Black as the pit from pole to pole,
I thank whatever gods may be
For my unconquerable soul.