At Lee & Ko, we focus on delivering the best tax advice and execution to achieve tax savings and mitigate tax exposure for our clients. By providing strategic and integrated tax solutions in the face of constantly changing legal and regulatory requirements; we allow our clients to focus on their core business activities.
The tax professionals at Lee & Ko are keenly aware of the changes to the global tax environment that are taking place and sensitive to tax policy shifts that can impact your business on a day-to-day basis. We stay tuned to all critical aspects of new tax developments in the business world both in Korea, as well as abroad. By addressing tax issues simultaneously from both the domestic and international perspectives, we provide comprehensive and proactive tax advice to our clients seamlessly across numerous jurisdictions.
As a fully integrated Tax Group, we maintain the highest practice standards to provide industry specific solutions to our clients so that they can stay ahead of current market trends and when appropriate, effectively respond to the dynamics of change. Our integrated approach to handling tax matters, working closely with all of our practice groups, provides effective and cost efficient business-oriented solutions to our clients.
■ Inbound and Outbound Tax Planning
Lee & Ko’s outbound tax team provides for specific business and tax needs with extensive experience in Korea and abroad in developing cross-border tax planning strategies. Our strategies focus tax efficient cash repatriation, exit planning in redeployment of funds, structuring and designing a tax efficient structure via a mix of debt and equity investment.
With highly specialized and dedicated tax professionals in all aspects of transactions and structuring, we help design and implement optimal corporate tax structures and provide relevant tax advices tailored to our clients’ specific needs. In line with such efforts, our outbound tax team has been very successful in recent years in transfer pricing matters for a number of clients whose manufacturing facilities are located in Southeast Asian countries including Indonesia, Vietnam, China, as well as dealing with tax dispute resolution cases in such jurisdictions.
On inbound tax planning, designing and setting up tax efficient investment structures is among others an important component to a successful investment in Korea. Likewise, when opportunities arise for our Korean clients to invest in the global market, we provide well-crafted tax planning and structuring ideas so that overseas investment can be made tax efficiently and with minimal tax risks. Our inbound tax team’s core offering is to assist foreign companies in structuring their Korean operations and investments tax-efficiently, which includes obtaining qualified tax reductions and exemptions under several tax-incentive regimes that are available for foreign direct investment.
■ Corporate Transactions and Structuring
Our tax specialists are frequently involved in assisting domestic and multinational clients with mergers, divestitures, asset or share transfer and holding company structures. The needs and demands for restructuring and cross-border mergers and acquisitions are expected to continue under the ever-changing global market conditions and as Korean companies continue to expand globally. At the same time, foreign companies are increasingly seeing Korea as an important market in which they need to be present and effective tax planning is becoming critical for their commercial success.
With highly specialized and dedicated tax professionals in all aspects of transactions and structuring, we help design and implement optimal corporate tax structures and provide relevant tax advices tailored to our clients’ specific needs, whether they relate to streamlining and restructuring of existing businesses or developing long-term plans and strategies for a business yet to be launched.
We have been extensively involved in a diverse range of mergers and acquisitions, corporate restructurings and internal reorganizations in both cross-border and domestic settings. With substantial experience going back to the early days of the “IMF Crisis,” our professionals are fully prepared to assist our clients develop appropriate restructuring plans that are designed to focus on core businesses while minimizing potential business risks of those businesses that are failing or has failed.
■ Transfer Pricing
With all the technical jargons aside, transfer pricing is all about understanding the taxpayers’ day-to-day business operations and how value is created along with the various functions that make up the manufacturing and distribution supply-chain. Such understanding is critical for complying with the arm’s length principle that governs the transfer pricing rules through the jurisdictions that are members of the OECD.
We have significant experiences handling all aspects of transfer pricing projects. Our transfer pricing team is unique in that it is comprised of not only attorneys, accountants and former tax officials that have transfer pricing experiences, but the team also includes economic specialists that understand the economic aspects of transfer pricing and can provide a detailed economic rationale for the transfer pricing method adopted by taxpayers.
We have witnessed great changes taking place in the transfer pricing realm in past years due to the implementation of OECD G20 BEPS (Basis Erosion and Profit Shifting) project, comprised of fifteen (15) action plans in a bid to deter tax evasion and profit shifting attempts by multinational enterprises. Among these, four action plans relate to transfer pricing. The keyword in these four action points is “value creation” and this will entail a precise analysis of an organization’s value chain, identifying value drivers or profit potentials and their migrations along that value chain.
We can assist more quickly and cost-effectively because the team has substantial practical experience handling complex, industry specific technical data and converting them into standard transfer pricing documentation that supports a robust, tax audit proof, transfer pricing policy.
In addition to transfer pricing documentation, the team can also assist clients with audit defense against tax audits, Mutual Agreement Procedures (MAPs) and Advance Pricing Agreements (APAs), structuring of tax-efficient supply chain management and designing of global transfer pricing policy.