Practices - BAE, KIM & LEE LLC

Overview

The Korea International Tax & Investment Center(“KITIC”) at Bae, Kim & Lee LLC (BKL) was established in January 2026 to respond to the profound transformations in the global economic landscape, including the realignment of supply chains and the increasing complexity of cross-border capital movements. As international tax becomes a core strategic element of business management rather than an optional consideration, our Center provides a seamless, "One-Stop Service" covering the entire lifecycle of your investment—from market entry and operation to risk management and exit.

KITIC operates as a dedicated task force comprised of Korea’s top experts, including former high-ranking officials from the National Tax Service and the Ministry of Economy and Finance, alongside leading specialists in finance, customs, and foreign exchange. Through this multi-disciplinary collaboration, we deliver precise and appropriate solutions for complex issues such as the Global Minimum Tax (Pillar 2), transfer pricing, and changing tax incentives.

We support clients by designing optimal investment structures, securing maximum government incentives, and proactively navigating tax audits and disputes. Beyond serving as a legal advisor, the Korea International Tax & Investment Center is committed to being your trusted strategic partner, offering reliable guidance to turn your global vision into reality within the dynamic Korean market.

Key Services

Inbound Investment Advisory Services

Market Entry: Designing optimal investment structures; securing tax incentives and government cash grants for foreign investments; and conducting tax due diligence reviews and advising on acquisition structures for M&A transactions.

Operations: Developing transfer pricing policies and responding to tax audits; managing regulatory developments, such as the Global Minimum Tax (Pillar Two); conducting permanent establishment risk assessments; and advising on customs, trade (regarding FTA verification and anti-dumping matters), and foreign exchange compliance.

Dispute & Exit: Defending tax audits; handling tax appeals and administrative lawsuits; and formulating repatriation strategies for liquidation and asset disposal.

Outbound Expansion Advisory Services

Planning: Advising on optimal jurisdictions and holding company structures for overseas expansion; and establishing global tax strategies (by conducting BEPS risk assessments).

Local Operations & Management: Advising on the management of overseas subsidiaries (regarding dividend policies and cash pooling); supporting local tax compliance; and structuring cross-border transactions between headquarters and overseas entities (in connection with royalties, services, etc.) and preparing transfer pricing documentation.

Risk Management: Formulating response strategies for foreign tax audits; and conducting mutual agreement procedures and advance pricing agreements to resolve double taxation risks.

Specific Advisory Services

Industry-Specific Advisory Services: Providing tailored professional solutions reflecting the specific characteristics of each sector, including semiconductors and batteries (manufacturing), IT and digital businesses (digital taxation), pharmaceuticals and biotechnology (R&D tax credits), and energy and natural resources (resource development)

Education & Networking: Hosting seminars for CFOs and working-level professionals of multinational enterprises; and leveraging global professional networks, such as the International Fiscal Association.

Practice Areas

Representative Cases

Advised Hana Financial, Shinhan Alternative Investment and Carlyle Group on establishing an infrastructure investment fund and making investments

Advised Comcast on tax issues relating to establishment and operation of a JVC with SKT

Advised on tax issues in relation to earnings from and withholding taxes on cryptocurrency transactions

Advised Phillip Morris on tax issues relating to the launch of heat-not-burn electric cigarettes

Advised Tesla on tax issues relating to establishment of its presence in Korea

Tax appeal dealing with issue of whether patent royalty is Korean source income

Represented a Chinese bank in a tax appeal to the Tax Tribunal and litigation in relation to foreign tax credit on taxes paid in a foreign jurisdiction

Tax litigation seeking revocation of a corporate tax imposition relating to an overseas resources development project

Represented the ROK in the LoneStar ISD Case

Represented Oriental Brewery in a litigation for revocation of corporate income taxes involving the issue of beneficial ownership on dividend payments from OB to SPC Group

Prepared the transfer pricing report for a Korean subsidiary of a foreign corporation

Prepared the advance pricing agreement for a foreign semiconductor company

Represented a Korean textile and apparel corporation in a transfer pricing audit

Represented a foreign auto parts company in a tax audit involving permanent establishment issues

Advised majority shareholders of a domestic major corporation on U.S. FATCA compliance requirements

Represented a domestic major corporation in a tax audit relating to effective place of management

Prepared reports on allocation of intra-group service fees within a foreign group company

Assisted a European industrial machine manufacturing company in a customs evasion investigation related to the import of laser welding machine

Assisted a Korean company in responding to a customs audit for alleged smuggling and false declarations involving exportation of cosmetics products to China

Assisted a Korean ship operator in responding to a customs audit for alleged omission of import declaration for bareboat charter

Assisted a multinational IT company in responding to audit for alleged smuggling based on the omission of import declaration for material used in the research and development of medical products

Assisted a Korean company in responding to an audit for illegal importation based on wood pellet importers’ omission of wood size/quality inspections

The first Supreme Court judgment that specified the illegality of a customs authority’s imposition of customs duties based on duplicated audits

The first court judgment that customs and VAT shall not be imposed on the grounds that the omission of a shipping-out declaration in transferring foreign goods between bonded factories was considered smuggling

Case involving a fine for negligence for violation of the Foreign Exchange Transaction Act in connection with virtual currency arbitrage

Lawsuit for appropriateness of customs value of medical device imported by a multinational medical device company

Tax Tribunal case with respect to whether various crude oils used in oil refining process constituted the same raw material, the object of refund under the Act on Special Cases Concerning the Refund of Customs Duties, Etc. Levied on Raw Materials for Export

Key Contacts

Our Team

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Korea International Tax & Investment Center

Overview

Key Services

Practice Areas

Representative Cases

Key Contacts

Practice Areas

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