Tax

"They provide the total package of advice and do not only provide advice on matters they are asked for, but try to look at the whole picture. They endeavour to integrate clients' commercial needs as much as legally possible."

- Chambers & Partners Asia-Pacific

Overview

Our Tax Group provides our clients with comprehensive and diverse legal services ranging from tax advice on a discreet matter to representation in tax litigations, relating to different tax issues that our clients face in the course of conducting their business activities, including M&A and other corporate restructuring, investment projects, trades and transactions, asset transfers and capital transactions, and other tax issues such as inheritance planning and gift transfers.

In order to provide our clients with effective and efficient solutions to different tax issues, our Tax Group consists of a team of attorneys with extensive experience in tax law, certified tax accountants having accumulated hands-on experience at the National Tax Service and other governmental agencies, and certified public accountants with in-depth experience in providing tax advice. Our Tax Group has experience in advising clients on tax-efficient strategies and successfully representing clients in various appeals proceedings, including litigation at the Tax Tribunal. Our Tax Group also works closely with the attorneys and professionals in other practice groups to provide comprehensive solutions on general tax, international tax, and transfer pricing matters.

Key Services

Tax Audit
Pre-audit reviews in preparation for tax audits
Tax audit defense strategies
Tax audit assistance
Advice on preparation of explanatory papers and written confirmations
Tax Disputes
Tax appeals (request of adequacy of tax imposition/objection to the competent regional tax office/appeal to the NTS or the Board of Audit and Inspection/appeal to Tax Tribunal)
Request for refund
Tax litigation (administrative/criminal/civil/constitutional)
Tax Consulting
M&A and corporate restructuring
Foreign investments
Overseas investments
Finance tax
Real estate
International Tax
Advice to foreign corporations on investments in Korea
Advice to domestic corporations on offshore investments
Advice on tax issues relating to permanent establishment and transfer pricing
Assistance with tax audits and tax regulations by tax authorities
Advice on legislative proposals
Tax appeals dealing with international tax issues
Transfer Pricing
Preparation of transfer pricing reports
Application for advance pricing agreement (APA)
Representation of clients in transfer pricing audits
Advice on foreign finance accounts

Representative Cases

Represented KORAIL in a lawsuit relating to rejection of a corporate tax refund claim in the amount of approximately KRW1 trillion, with respect to the termination of a purchase agreement in the Yongsan International Business District
Represented KT in an appeals lawsuit relating to a rejection of VAT refund in relation to cellular phone subsidies
Advised LGU+ in relation to merger and spin off in the course of restructuring its MVNO business
Tax Audit
Represented a major construction and trading corporation in a tax audit
Represented a major liquor importer in a tax audit
Represented a major terrestrial broadcasting system in a tax audit
Represented a major securities firm in a tax audit
Tax Disputes
Represented KORAIL in a lawsuit relating to rejection of a corporate tax refund claim in the amount of approximately KRW1 trillion, with respect to the termination of a purchase agreement in the Yongsan International Business District
Represented UBS Securities in a lawsuit seeking revocation of imposition of corporate tax in relation to ELW
Represented Samsung C&T and Hyundai Corp. in tax appeals to the Tax Tribunal for revocation of imposition of corporate tax in relation to their overseas resources development projects
Represented KT in an appeals lawsuit relating to a rejection of VAT refund in relation to cellular phone subsidies
Represented Oriental Brewery in a lawsuit seeking revocation of corporate tax imposition in relation to withholding tax on dividend payments from OB to SPC Group
Tax Consulting
Advised LGU+ in relation to merger and spin off in the course of restructuring its MVNO business
Advised Kakao on tax issues relating to acquisition of shares in Kakao Bank
Advised SeAH Group on tax issues relating to spin offs and conversion to a holding company
Advised Hana Financial, Shinhan Alternative Investment and Carlyle Group on establishment of infrastructure investment funds
Advised Hana Financial Holding on tax issues in relation to the acquisition of certain subsidiaries
Advised Shinhan Life Insurance on tax issues in relation to purchasing structure of L Tower
International Tax
Represented a Chinese bank in a tax appeal to the Tax Tribunal and a litigation in relation to foreign tax credits
Advised Comcast on tax issues relating to establishment and operation of a JVC with SKT
Advised on tax issues in relation to income beneficiary and withholding taxes from cryptocurrency trading
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