Satoru Araki Head of Advisory - Tax, Partner

Dr Satoru Araki joined Forvis Mazars in April 2025. Satoru provides tax advisory services on tax planning and controversy for both inbound and Japanese multinationals as Head of Advisory.  ​

Immediately before joining Forvis Mazars, Satoru was chiefly engaged in tax advisory services for companies as a Director of Tax Advisory Group at a Big Four tax firm.

Satoru started his career at the National Tax Agency of Japan, and lead tax audit and controversy cases as Assistant Regional Commissioner.

Satoru also formulated international standards as Principal Administrator at the OECD secretariat in Paris.

Satoru has written books and articles widely on tax and financial services in English, French, Japanese and Spanish. 

Expertise

・Tax planning

・Tax controversy

・International taxation issues 

・Consultation with the tax authorities

・Tax incentives

・Tax policy research
 

Recent publication

Date: October 13, 2025

Article Title: Japan’s New Undertaxed Profits Rule And Domestic Minimum Top-Up Tax: Multinational Enterprise Perspective
Japan’s New Undertaxed Profits Rule and Domestic Minimum Top-Up Tax: Multinational Enterprise Perspective | Tax Notes

In this article, Satoru Araki explains the 2025 tax reforms in Japan, which introduce the undertaxed profits rule and a qualified domestic minimum top-up tax as part of the global minimum tax package promulgated by the OECD, and their potential effect on Japanese entities of multinational enterprises.

Date: May 14, 2025

Article Title: The Discretionary Grant of Tax Treaty Benefits in Japan
The Discretionary Grant of Tax Treaty Benefits in Japan | Tax Notes

In this article, Satoru Araki examines the discretionary relief procedure in which a taxpayer who does not satisfy the entitlement-to-benefits conditions of a tax convention can still apply to a tax authority for the discretionary grant of tax treaty benefits.
 
 

Language capabilities include Japanese, English, French and Mandarin Chinese.