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Lee & Ko Hosts 2026 Tax Forum Addressing the August 2026 Tax Revision Bill and Recent Tax Audit Trends

Lee & Ko hosted the 2026 Lee & Ko Tax Forum, "Key Corporate Response Strategies in Light of the August 2026 Tax Revision Bill and Recent Tax Audit Trends," on Friday, August 28, at Ferrum Hall in Ferrum Tower, Jung-gu, Seoul.

The Forum analyzed the 2026 Tax Revision Bill announced on August 3 and recent tax audit developments, along with their practical implications for businesses. Registration closed ahead of schedule, drawing approximately 200 corporate representatives to a capacity crowd at Ferrum Hall. The sessions focused on the most consequential reforms: the taxation of treasury shares, new valuation rules for listed shares addressing so-called "share price suppression," tax deferral for qualifying corporate divisions and other restructurings of foreign subsidiaries, and the redesign of Korea's family business succession tax regime.

The Forum opened with welcoming remarks from Ok Hyun Ma, Co-Head of Lee & Ko's Tax Group, and was moderated by Sang Hoon Kim, also Co-Head of the Tax Group.

In a keynote preceding the main sessions, Jin Gyu Choi, Director of the Tax Policy Division at the Ministry of Finance and Economy ("MOFE"), delivered "Key Features and Policy Implications of the August 2026 Tax Revision Bill," setting out the principal policy objectives and rationale underlying this year's proposals. As Director of the Tax Policy Division, Mr. Choi oversees the government's tax reform agenda.

In the first session, Hansol Leem presented on "Proposed Tax Amendments Regarding Capital Transactions and Share Valuation." On treasury shares, Mr. Leem explained that the reforms mark a fundamental shift toward treating treasury share transactions as capital transactions regardless of the purpose of acquisition. Because materially different regimes will govern transactions before and after the January 1, 2027 effective date, he noted, companies must weigh the applicable treatment carefully when planning such transactions.

On the newly proposed valuation rules for listed shares targeting so-called "share price suppression," Mr. Leem advised companies to monitor their industry-relative price-to-book ratio (PBR) semiannually and keep contemporaneous documentation of the business rationale for key management decisions, positioning themselves to demonstrate the absence of a tax avoidance purpose. He also discussed the proposed Domestic Production Tax Credit, broadly similar in purpose and structure to the Advanced Manufacturing Production Credit under the U.S. Inflation Reduction Act, advising companies to review the product-specific base credit amounts expected early next year and weigh them against Korea's Integrated Investment Tax Credit to determine which regime is more advantageous.

The second session featured Min Gu Kim, who addressed "Key Developments in International Tax and Business Succession." Mr. Kim explained that the amendments would allow certain taxes arising from qualifying corporate divisions and other restructurings by foreign subsidiaries to be deferred, or the related income excluded from taxable income. Companies contemplating such restructurings should factor the new regime's effective date into their transaction timelines.

On business succession, Mr. Kim highlighted the newly proposed tax relief for third-party business succession, which would benefit both the controlling shareholder transferring the business and the third-party acquirer. He added that the proposal merits attention even from companies that have not viewed Korea's family business succession rules as directly relevant, as it could create new considerations and opportunities from an acquisition strategy and transaction-planning perspective.

In the final session, Tae Woo Kim, a certified tax accountant who previously served as Director of Investigation Division 1, Investigation Bureau 1 of the Seoul Regional Tax Office, presented on "2026 Tax Audit Trends and Risk Management." Mr. Kim examined the areas drawing particular scrutiny in audits of large corporations and broader changes in audit administration. He also addressed practical strategies for invoking and protecting attorney-client privilege ("ACP") during tax audits, in light of recent Supreme Court precedent and amendments to the Attorney-at-Law Act.

Closing the Forum, Sang Hoon Kim observed that the proposed reforms go well beyond technical amendments and contemplate significant changes to the existing tax framework, and he urged companies to begin assessing their impact even before the legislative language is finalized. He added that Lee & Ko's Tax Group will continue to deliver practical, tailored solutions and to share timely insights on significant legislative and regulatory developments.

Lee & Ko's Tax Group brings together more than 90 professionals, including attorneys, certified public accountants, and certified tax accountants. As an integrated, multidisciplinary team, the Group delivers seamless support across the full spectrum of tax matters, from tax advisory and international tax to tax audit defense, controversy, and litigation.

Lee & Ko has been recognized in the “ALB Asia Top Cybersecurity & Data Law Firms 2026” by Asian Legal Business (ALB). Newly introduced this year, the Cybersecurity & Data category recognizes leading law firms in the region for their expertise and capabilities in data privacy and cybersecurity.

Lee & Ko’s Technology, Media & Telecommunications (TMT) and Data Privacy & Cybersecurity (DPC) Practice Groups provide comprehensive legal services across the broadcasting, telecommunications, IT, data privacy and cybersecurity sectors. Drawing on extensive industry knowledge and regulatory experience, the Groups advise clients on a wide range of transactional and regulatory matters and represent them in regulatory investigations, enforcement proceedings and litigation. Recent notable representations include successfully defending Korea’s three major mobile network operators in a large-scale damages action brought by 5G mobile service subscribers. The Groups also represented SK Telecom (SKT) in Supreme Court litigation brought by subscribers seeking to prevent SKT from pseudonymizing their personal information, securing a favorable ruling for the company. In addition, the Groups advised SKT in connection with the Personal Information Protection Commission’s investigation and administrative disposition concerning the largest personal data breach involving a Korean mobile network operator to date, achieving the maximum reduction in the applicable administrative surcharge permitted under law. Through their extensive experience in handling complex and evolving legal and regulatory issues, Lee & Ko’s TMT and DPC Practice Groups continue to provide sophisticated and practical advice to clients while remaining at the forefront of developments in the cybersecurity and data privacy fields.

Asian Legal Business (ALB) is a leading legal publication in the Asia-Pacific region published by Thomson Reuters. Its rankings and awards recognize leading law firms and lawyers across the region based on factors including professional expertise, track record and client service.

Lee & Ko has once again been recognized as a Band 1 law firm in the Private Wealth Law category of Chambers High Net Worth 2026, published by Chambers and Partners. In the individual rankings, dispute resolution specialist Dong Ha Kim was ranked in Band 1 for the third consecutive year.

Lee & Ko recently secured a successful outcome in a USD 2 billion arbitration on behalf of a major shareholder of a Korean company. The firm also regularly advises on complex regulatory matters and represents chairpersons of leading Korean conglomerates in high-stakes disputes arising from corporate restructurings and reorganizations.

Drawing on its extensive expertise across a broad range of practice areas, Lee & Ko advises the owners and senior executives of major Korean conglomerates, as well as their families, on a wide range of legal and tax matters relating to the accumulation, management, transfer, and protection of personal wealth.

Dong Ha Kim, a leading dispute resolution practitioner at Lee & Ko, has been recognized as a Band 1 lawyer for the third consecutive year. Mr. Kim has extensive experience in both corporate advisory work and litigation. His principal areas of practice include commercial litigation, corporate law, healthcare, construction and real estate, government contracts, and family law.

Chambers High Net Worth is a leading international legal directory focusing on the private wealth sector and covers more than 55 jurisdictions, including Korea.

Su Jin Jung, a leading partner in Lee & Ko’s Litigation Group, has been named to Asian Legal Business (ALB) Asia Top Female Lawyers 2026, in recognition of her standing as a leading female practitioner in Asia and her success in major disputes, including the SK Telecom personal data breach case.

Ms. Jung joined Lee & Ko in 2023 after 20 years on the bench. Drawing on that experience, she has developed exceptional expertise across a broad range of complex disputes, including fair trade litigation, criminal cases arising from serious industrial and occupational accidents, personal data protection litigation, and corporate control disputes. She has secured acquittals in a series of such criminal cases, including the SK Multi Utility and SAMPYO Group cases, two of Korea's most significant serious accident cases, and the industrial accident case involving Samsung Electronics' Giheung facility. The SK Multi Utility case resulted in the first acquittal under the Serious Accidents Punishment Act involving an affiliate of a major Korean conglomerate, while the SAMPYO Group case attracted nationwide attention as one of the first major cases arising from a serious accident occurring after the Act took effect. She also leads a number of fair trade administrative litigation matters concerning abuse of market dominance, unfair trade practices, and violations of the Fair Transactions in Subcontracting Act. Ms. Jung further contributed to achieving a balanced resolution in dispute mediation proceedings before the Consumer Dispute Settlement Commission in connection with the SK Telecom personal data breach and has obtained timely and favorable decisions in several preliminary injunction proceedings arising from corporate control disputes.

Published by Thomson Reuters, a leading global provider of legal news and information, Asian Legal Business (ALB) is a premier legal publication covering the Asia-Pacific region. Each year, ALB selects its Top Female Lawyers from 13 jurisdictions across Asia, including Korea, Japan, India, Singapore, and Hong Kong, recognizing women lawyers who have achieved outstanding results over the course of their careers.

Vera Eun Woo Lee, a partner in Lee & Ko’s IP & Technology Group, has been named to Managing IP’s Top 250 Women in IP 2026. This recognition reflects her outstanding achievements in intellectual property law, including her successful representation of a major distribution company in a trademark infringement action seeking injunctive relief and damages.

Since joining Lee & Ko in 2004, Ms. Lee has advised and represented clients across the full spectrum of intellectual property matters, including patents, trademarks, copyrights, domain names, unfair competition, IP licensing, and employee inventions. She has also played a leading role in precedent-setting disputes involving novel issues arising from technological developments and evolving social trends.

Ms. Lee’s notable track record includes a landmark trademark infringement case on behalf of a major distribution company, as well as a wide range of complex and first-of-their-kind disputes involving copyright and unfair competition issues. These include a Supreme Court case that established important standards for copyright infringement involving game-related works, as well as cases concerning the scope of protection for copyrighted photographs and the unauthorized use of a long-standing mark.

Managing Intellectual Property, also known as Managing IP, is a leading publication in the intellectual property field. Each year, it recognizes senior female IP practitioners with outstanding accomplishments based on research and surveys of IP professionals worldwide.

Lee & Ko received a total of five awards at the Benchmark Litigation Asia-Pacific Awards 2026, including ‘Labour and Employment Firm of the Year,’ ‘South Korea Lawyer of the Year’ and ‘Client Choice – South Korea Firm of the Year,’ earning the distinction of being the most awarded Korean law firm at this year’s awards.

In the Practice Area Firm Awards category, which recognizes one leading law firm across the Asia-Pacific region in each of 11 practice areas, Lee & Ko was named ‘Labour and Employment Firm of the Year,’ underscoring the firm’s exceptional expertise in labour and employment law. Among its many notable achievements, Lee & Ko’s Labour and Employment Group successfully defended one of the world’s largest tyre manufacturers before the Supreme Court against serious allegations of illegal worker dispatch, thereby protecting the client’s business operations. The group also represented a major global automobile manufacturer in matters concerning an employer’s disciplinary authority and procedures.

In the ‘Lawyer of the Year – South Korea’ category, Lee & Ko’s Taeyop Lee was recognized for his outstanding achievements and contributions. Before joining Lee & Ko, Mr. Lee served as a public prosecutor, gaining extensive investigative experience in special investigations, finance and taxation, customs and foreign exchange, intellectual property—including trade secrets—and the healthcare and food sectors. Drawing on this background, he now leads criminal defense and general litigation matters at the firm involving intellectual property and trade secrets, personal information protection, broadcasting and telecommunications, foreign exchange and customs, and healthcare. In particular, he has built a strong reputation for guiding clients through major corporate criminal matters involving finance, trade secrets and serious accidents, consistently securing favorable outcomes and delivering the highest level of protection for his clients’ interests.

Lee & Ko also received the ‘Impact Case of the Year’ award for its representation of HSBC Bank in a criminal short-selling case. In that case, the firm persuaded the court to adopt a reasonable interpretation of the short-selling provisions under the Financial Investment Services and Capital Markets Act and secured a not-guilty verdict for its client.
In addition, Lee & Ko was named ‘South Korea Firm of the Year’ in the Client Choice Awards, which were announced in conjunction with the Benchmark Litigation Asia-Pacific Awards, while Foreign Attorney Steve Minhoo Kim was recognized as ‘South Korea Honourable Mention Lawyer of the Year.’ Based on client feedback and evaluations, the Client Choice Awards recognize excellence in client service. These accolades further demonstrate Lee & Ko’s differentiated client service and the high level of trust it has earned from its clients.

Benchmark Litigation is a globally renowned publication focusing on dispute resolution and litigation. Each year, it publishes rankings based on in-depth analysis of law firm submissions, as well as interviews with lawyers, clients and litigation experts.