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Tax Audit & Tax Dispute Resolution

"Largest tax practice in South Korea with a deep bench of tax specialists."
– Chambers Asia-Pacific 2019

Overview

Our Tax Audit & Tax Dispute Resolution Practice focuses on protecting taxpayers’ rights in tax audits and tax controversy matters.  In particular, we provide a full range of tax dispute resolution services, representing taxpayers in tax audits and administrative appeals to the Tax Tribunal or the Board of Audit and Inspection.

Our Practice is supported by over 100 attorneys and CPAs, and over 50 former officials from the National Tax Service, the Ministry of Economy and Finance, the Tax Tribunal, the Korea Customs Service and the Board of Audit and Inspection.  The diverse and unique background of our professionals enables us to develop creative and persuasive arguments or solutions in tax ruling requests, tax audits and administrative tax appeals.  

Our Practice has consistently been recognized as the leading firm in tax law and has been recognized in several leading global legal publications such as Chambers Asia-Pacific, The Legal 500 Asia Pacific, Asialaw Profiles and International Tax Review.

Key Servicesshow

Tax Audit Assistance

The Tax Audit team of our Practice assists clients in all phases of tax audits including audit preparation and defense and all types of audits, including regular tax audits, special investigations, search and seizure audits, inheritance and gift tax audits and individual tax audits.  The scope of our service also encompasses pre-audit diagnosis of key issues, such asmock tax audits or tax health checks, and post-audit issue rectification.  Our Practice consists of a balanced mix of former tax auditors of the National Tax Service, accountants and attorneys, with extensive field audit experience. 

 

Tax Dispute Resolution

The Tax Dispute Resolution team of our Practice is composed of attorneys (including former Supreme Court justices and High Court or District Court judges), former Tax Tribunal officials and other experienced tax professionals.  We assist clients in tax appeals at the National Tax Service administrative appeal procedures, including pre-assessment and post-assessment appeals, and the Tax Tribunal.  Each group assigned to a client takes into account the client’s needs and is customized to address specific issues and demands of the case by deploying an optimal mix of former judges, tax attorneys and other professionals familiar with the specific issues and individuals involved in the case. 

Key Experiencesshow

On average, Kim & Chang assists clients in over 100 tax audits and 300 tax disputes annually. 

 

Recent cases include:

 

Administrative Tax Appeals (Tax Adjudication & Review of Adequacy of Tax Imposition (“RATI”))
  • Favorable Tax Tribunal judgment involving sales incentives and overseas advertising expenses.
  • Favorable Tax Tribunal judgment on “share-ownership” requirements to qualify for reduced dividend withholding rates under the Korea-US Tax Treaty.
  • Favorable Tax Tribunal judgment regarding substance-over-form rules in the context of offshore funds.
  • Favorable Tax Tribunal decision allowing deduction of legal costs and compensatory damage payments in an overseas collusion case.
  • Favorable Tax Tribunal judgment regarding the amortization of goodwill acquired in a merger.
  • Favorable Tax Tribunal judgment involving inheritance and gift tax issues associated with family operated business.
  • Favorable Tax Tribunal judgment regarding the treatment of retired treasury stock.
  • Favorable RATI decision involving the allocation of common expenses and associated VAT invoice issuance issues.
  • Favorable RATI decision involving losses carried over in a reverse merger.

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