International Tax Team consists of Korean and foreign licensed lawyers with extensive experiences in international taxation through their previous work at leading overseas law firms and multinational companies, certified public accountants with their previous experiences in international taxation at large domestic and foreign accounting firms, experts in transfer pricing and tax attorneys from the National Tax Service with acknowledged competencies in international taxation area. The Team strives to maximize client satisfaction by providing a full range of legal services on international taxation which include advising multinational companies on tax issues in relation to their corss border transactions, advising domestic companies on tax issues in relation to their outbound transactions, advising on tax issues in relation to joint ventures and investment funds, and advising on advance pricing agreement (APA) and transfer pricing.
Major Practice Areas
- Advising multinational companies on tax issues in relation to their international and domestic transactions
- Advising domestic companies on tax issues in relation to their outbound transactions
- Structuring joint ventures and investment funds
- APA (Advance Pricing Agreemennts)
- Advising on transfer pricing
- Advised on Net 1 Technologies’ acquisition of stocks and management rights of KS Net
- Advised Seagate Technology on its acquisition of Samsung Electronics' HDD business
- Successfully represented STATS ChipPAC Korea, a global semiconductor test and packaging service provider, in Tax Tribunal cases in relation to the interpretation of tax treaties.
- Successfully represented Coca-Cola in a tax appeal before the Tax Tribunal and won full cancellation of VAT.
- Successfully represented Louis Vuitton Korea in a tax appeal before the Tax Tribunal.
Tax Legislative Services
- Provided services for the Ministry of Strategy and Finance with respect to it's contemplated reform of transfer pricing tax regime in Korea.
- Conducted a tax legislative support project on behalf of a consortium of foreign multinational companies which led to amendment of the Korean tax laws and regulations to allow deduction for cost of equity stock compensation provided to employees of the Korean subsidiary or branch.
- Conducted SK Global Chemical’s Korea-China APA
- Theory and Practice of Law on International Tax (Co-authored) (2014, 2012, 2011)
- Verification Issues Affecting the Korea-EU FTA, ABA Section of International Law, Customs Law Committee Newsletter (2014)
- "How to Bridge the Gap between Transfer Pricing and Customs Valuation", Tax Notes International (September 2013)