International Tax

"They are on time with work and always reachable, which is very important."

- Chambers & Partners Asia-Pacific

Overview

Our Tax Group provides clients with comprehensive legal services on tax issues arising in relation to inbound investments by foreign corporations and outbound investments by domestic corporations based on our expertise with the recent trends of the world economy and the international tax environment. In particular, international tax practice involves dealing with a wide variety of issues in different jurisdictions, including international tax disputes regarding the jurisdictional authority of multiple countries and fairness of tax imposition, requiring a far more detailed review and management of potential risks than any other area of the tax law. Our Tax Group provides optimal solutions to address such risks through a dedicated team of attorneys, certified public accountants, and certified tax accountants with wide-ranging experience and knowledge.

Professionals with High-Caliber Expertise and Global Network

International tax has recently seen a number of important issues being raised, including the introduction of BEPS or digital tax, and discussions on such topics have been taking place on a global level. Under these circumstances, the Korean tax authorities have become even more aggressive in conducting tax audits, by regulating tax havens and in seeking offshore sources of tax revenue. Our Tax Group, consisting of attorneys, certified public accountants and certified tax accountants, provide legal services based on the broad range of experience and expertise accumulated from their various backgrounds, including the courts, the National Tax Service, the Tax Tribunal, the Ministry of Strategy and Finance, and multinational corporations. In particular, as international tax law is very closely dependent on international trends, our Tax Group maintains a global network of law firms working in coordination to provide our clients with unparalleled service.

Comprehensive Solutions for Clients

International tax issues demand an integrated review of domestic/foreign tax laws and tax treaties to determine taxing rights between countries where tax impositions issued in one or more jurisdictions are at issue. In addition, it is imperative that the response to cross-border tax risks and challenges be appropriate in light of recent tax practices and trends. Our Tax Group provides comprehensive solutions to achieve best outcome for our clients, based on our outstanding expertise and in-depth understanding of international tax practices.

Key Services

Tax Advice on Cross-Border Transactions
Advice on inbound investments by foreign entities
Advice on outbound investments by Korean entities
Advice on tax issues relating to permanent establishment and transfer pricing
Representation in tax audits and tax regulations by tax authorities
Advice on tax legislation
Tax Appeals Relating to Cross-Border Transactions
Objection to the competent regional tax office, tax appeal to the National Tax Service or the Board of Audit and Inspection, tax appeal to the Tax Tribunal, and tax litigation relating to cross-border transactions
Requests for tax refund claims
Representation in prosecutor investigations and criminal litigation relating to cross-border transactions

Representative Cases

Advised Phillip Morris on tax issues relating to the launch of heat-not-burn electric cigarettes
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
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
Tax Advice on Cross-Border Transactions
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 Appeals Relating to International Tax
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