Transfer Pricing

• Successfully defended a U.S.-based OLED materials company in a transfer pricing tax audit.

• Successfully defended a U.S.-based food franchise company in a transfer pricing tax audit.

• Successfully defended a U.S.-based life insurance company in a transfer pricing tax audit.

• Successfully defended a U.S.-based game development company in a transfer pricing tax audit.

• Provided advisory services on global transfer pricing policy development for major conglomerates across various industries in Korea.

• Represented a footwear manufacturer in a bilateral Advance Pricing Agreement (APA) negotiation between the Directorate General of Taxes (DGT) of Indonesia and the National Tax Service (NTS) of Korea.

• Represented a Korean trading company in a bilateral APA negotiation between the Directorate General of Taxes (DGT) of Indonesia and the National Tax Service (NTS) of Korea.

• Represented a Korean manufacturing company in an APA and Mutual Agreement Procedure (MAP) negotiation between the Canada Revenue Agency (CRA) and the National Tax Service (NTS) of Korea.

• Represented a German automobile manufacturer in a bilateral APA negotiation between the German Federal Central Tax Office (BzSt) and the National Tax Service (NTS) of Korea.

• Advised Korean corporations on handling overseas transfer pricing tax audits and litigation support.

• Prepared transfer pricing documentation, including BEPS Local File, Master File, and Country-by-Country (CbC) Reporting, for domestic and foreign-invested corporations.

• Provided advisory services on transfer pricing policy development related to management service fees and their deductibility for Korean and foreign-invested enterprises.

• Conducted transfer pricing policy assessments and prepared reports on the arm’s length pricing of guarantee fees for major Korean conglomerates.

Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)

• Advised foreign-invested enterprises on domestic tax and international tax issues, including corporate income tax, individual income tax, VAT, and tax credits.

• Provided advisory services on permanent establishment (PE) risks and transfer pricing issues related to the incorporation of foreign-invested entities in Korea.

• Assisted foreign-invested enterprises in evaluating unlisted stock valuations under the Inheritance and Gift Tax Act and the Income Tax Act in relation to restructuring and governance changes.

• Advised foreign-invested enterprises on tax implications related to corporate restructuring, including mergers and acquisitions.

• Represented foreign-invested enterprises in withholding tax exemption or reduced withholding tax rate applications under tax treaties.

• Prepared transfer pricing reports to determine arm’s length price in domestic related-party transactions governed by the Korean Corporate Income Tax Act.

• Provided advisory services and litigation support on income characterization (e.g., business income vs. royalty income) and beneficial / substantial ownership issues for foreign-invested enterprises.

Outbound Tax Advisory (Overseas Investment Tax Services)

• Provided tax structuring advice for Korean corporations investing overseas or establishing foreign subsidiaries, including assessments of tax risks related to VAT, permanent establishments, transfer pricing, corporate tax, and withholding tax in the target jurisdiction.

• Advised domestic investment funds on tax implications related to overseas real estate investments.

• Assisted Korean corporations in managing and responding to tax litigation in foreign jurisdictions.

• Global Practice Guides: Tax Controversy 2024 : Q&A: South Korea, May 16, 2024, Chambers & Partners
• Speaker at IFA Hong Kong 2024 Asia Pacific Regional Tax Conference, April 22, 2024
• Transfer Pricing Guide 2024, Korean Chapter, April 11, 2024, Chambers & Partners
• Monthly International Tax Forum on November 2023, hosted by IFA Korea, Panelist of the first topic “Transfer pricing implication of Pillar 1”
• International Tax and Transfer Pricing lecturer for Zakat, Tax and Customs Authority (ZATCA) in Saudi Arabia, October 2023
• Korean chapter of Transfer Pricing, August 2023, Lexology, Getting The Deal Through (GTDT)
• South Korea First to Enact Global Minimum Tax Rules Amid Concerns, July 2023, Bloomberg Tax
• The Corporate Tax Planning Law Review, May 2023, The Law Review
• Distinctive Feature of South Korea’s Regulation and Local Practice Concerning Attribution of Profits to Permanent Establishment, November, 2022, Tax 2022 Expert Guide - CorporateLiveWire
• Transfer Pricing Lecturer at Korean Customs Service (KCS)
• Presenter at the OECD Korea Policy Centre with a topic “Transfer Pricing of Financial Transactions,” January 2022
• Transfer Pricing Lecturer - The Graduate School of Science in Taxation (GSST) at University of Seoul
• Transfer Pricing Guide 2022, Korean Chapter, April 14, 2022, Chambers & Partners
• Intercompany Loan Transaction: Recent Development in South Korea’s Transfer Pricing Regime, February 20, 2022, Bloomberg Tax
• Transfer Pricing Guide 2021, Korean Chapter, April 7, 2022, Chambers & Partners
• IFA Korea Tax Webinar, Session 4 (Impact of COVID-19 on Transfer Pricing) Panelist
• South Korea - Trend in Transfer Pricing, November 16, 2020, Bloomberg Tax
• South Korea - Trend in Permanent Establishment, October 21, 2020, Bloomberg Tax
• New South Korea Transfer Pricing and Diverted Profit Tax Laws enter into Effect, April 16, 2020, MNE Tax
• Korean Tax Law Adopts New Simplified Transfer Pricing Rules relating to Low Value-adding Intra-group Services, January 20, The Legal 500