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Tae-Yeon NAM Tax Attorney/CPA

T.+82-2-3703-1028 F.+82-2-737-9091/9092
Tae-Yeon NAM Tax Attorney/CPA
Tae-Yeon NAM Tax Attorney/CPA

Tae-Yeon NAMTax Attorney/CPA

T.+82-2-3703-1028 F.+82-2-737-9091/9092 E.tynam@kimchang.com

Areas of Expertise

Bio

Tae-Yeon (TY) Nam is a tax attorney/certified public accountant at Kim & Chang. She practices primarily in transfer pricing, general tax consulting, and tax audit and dispute resolution.

Ms. Nam has been working as a tax attorney with the firm since the transfer pricing regime was first introduced to Korea in 1996. She focuses on international taxation and transfer pricing. Ms. Nam works on transfer pricing analysis and planning and representing clients in tax audits and disputes, including domestic tax appeals and Mutual Agreement Procedures (MAP) between Korea and tax treaty partner countries. Her key areas of expertise include filing and negotiations on the Advance Pricing Agreements (APA) with tax authorities.

With a wide range of industry knowledge from practicing in an accounting firm and an international finance division in an investment securities company, Ms. Nam was involved in Korea's first successful bilateral/unilateral APAs. As a leading member of the firm’s transfer pricing practice, she has successfully advised on more than hundred APAs/MAPs for clients in major industries including pharmaceuticals, IT, automobiles and parts, consumer goods, fashion and boutiques, chemicals, motion pictures and finance, such as banking, securities and private equity funds.

Prior to joining the firm, Ms. Nam worked for Arthur Andersen Co. in Seoul from 1992 to 1995 and for one of the leading investment securities companies in Korea from 1995 to 1996. In 2002, she also worked in the International Bureau of Fiscal Documentation (IBFD) in Amsterdam, as a research associate focusing on Korean transfer pricing and APAs.

Ms. Nam has published her work in various transfer pricing related publications, including "Transfer Pricing in Korea" (IBFD). She has been honored by the Minister of Strategy and Finance for her expertise in 2009. She has been a frequent lecturer for transfer pricing related subjects at the National Tax Officials Training Institutes since 2008.

Ms. Nam received a Master of Professional Accounting specialized in Tax from the School of Business Administration, University of Washington, Seattle in 2002 and a B.A. from the College of Business and Economy, Dongguk University in 1989. She is a certified public accountant of Korea.

Profile

Experience

International Bureau of Fiscal Documentation (2002-2003)

Kim & Chang (1996-Present)

International Finance Division, Ssangyong Investment Securities Co., Ltd. (1995-1996)

Arthur Andersen Co., Seoul (Anjin Accounting Corporation) (1992-1995)

Representative Mattersshow

APA/MAP
 
  • Korea’s first bilateral APA for tangible goods transaction between Korea and US. 
  • Korea’s first unilateral APA for royalty transaction between Korea and US. 
  • Bilateral APA for the world’s largest semiconductor company. 
  • Bilateral APA/MAP for world’s leading construction equipment company. 
  • Korea-US MAP for transfer pricing of tangible goods, royalty, commission and service transactions for world’s leading chemical company. 
  • Unilateral APA for a global leading investment bank for global trading and other banking transactions. 
  • Unilateral APA for global pharmaceutical company. 
  • Unilateral APA for world’s leading medical device company. 
  • Unilateral APA for world’s largest IT storage company. 
  • Korea-China Bilateral APA/MAP for Korea’s largest construction equipment company. 
  • Korea-China Bilateral APA/MAP for Korea’s leading electronic company. 
 
Tax Audit Defense and Dispute Resolution
 
  • Various tax audit defense projects for a broad spectrum of clients in the chemical industry, automobile and parts industry, semiconductor industry, fashion, boutique and cosmetics industry, electronics and IT industry, pharmaceutical industry, banking and securities industry, insurance industry, private equity funds, etc. 
  • Various dispute resolution projects for clients through all level of tax appeal procedures and MAP especially for transfer pricing and international tax issues. 
 
Transfer Pricing Planning and Analysis
 
  • Global transfer pricing policy set-up project for a client in the machinery industry for a Korean parent company and offshore subsidiaries. 
  • Transfer pricing set-up project for a client in the consumer industry based on business restructuring. 
  • Transfer pricing analysis and consulting projects for a broad spectrum of clients including a global mobile device manufacturer, a medical instrument and device distributor, a pharmaceuticals company, a telecommunication equipment company, an asset management service provider, a bank with brokerage, capital market service, M&A advisory service and other banking services, private equity funds, and an insurance company. 
 
Customs Valuation and Customs Audit Defense
 
  • Advance Customs Valuation Approval (ACVA) projects for a client in the cosmetics industry. 
  • Consulting projects on transfer pricing and customs valuation for clients in various industries including the pharmaceutical industry.

Representative Activitiesshow

Awards

  • Transfer Pricing Lawyer of the Year, Asia Women in Business Law Awards (Euromoney, 2021-2022)
  • Leading Practitioner, Who’s Who Legal: Korea, Corporate Tax (Who’s Who Legal, 2021, 2023)
  • Leading Practitioner, Expert Guides - Women in Business Law: Transfer Pricing (Expert Guides, 2020-2022)
  • Highly Regarded, World Tax: Korea, Tax (International Tax Review, 2020)
  • Highly Regarded, World Transfer Pricing: Korea, Transfer Pricing (International Tax Review, 2020)
  • Leading Individual, The Legal 500 Asia Pacific: Tax (Legalease, 2019-2024)
  • Best in Transfer Pricing, Asia Women in Business Law Awards (Euromoney, 2015, 2018)
  • Leading Individual, Chambers Asia-Pacific, Tax: Consultants (Chambers and Partners, 2014-2024)
  • Citation from the Minister of Strategy and Finance (2009.3.)

Publications/Activities
    • Transfer Pricing and Customs Valuation - A Korean Perspective, International Transfer Pricing Journal Vol.28 No.4 (Co-author, IBFD, 2021) 
    • Getting the Deal Through - Transfer Pricing: Korea chapter (Co-author, Law Business Research, 2018) 
    • Asian Voices: BEPS and Beyond - Korea chapter (Co-author, IBFD, 2017) 
    • Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies - Korea chapter (Co-author, Wolters Kluwer Law & Business, 2014) 
    • Transfer Pricing in Korea for the Tax Treatment of Transfer Pricing (Co-author, IBFD, 2008) 
    • Thin Capitalization: South Korea, Asia-Pacific Tax Bulletin Vol.11 No.5 (Co-author, IBFD, 2005) 
    • Transfer Pricing in Korea: the APA experience, Asia Transfer Pricing (Co-author, International Tax Review, 2004) 
    • Advance Pricing Approvals, Asia-Pacific Tax Bulletin Vol.9 No.7 (Co-author, IBFD, 2003)

Education

    School of Business Administration, University of Washington, Seattle (Master of Professional Accounting specialized in Tax, 2002)

    College of Business and Economy, Dongguk University (B.A., Accounting, 1989)

Qualifications

    Certified Public Accountant, Korea, 1992

Languages

Korean and English

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Tae-Yeon NAM
Tax Attorney/CPA


T. +82-2-3703-1028      
F. +82-2-737-9091/9092
     


  




Tae-Yeon (TY) Nam is a tax attorney/certified public accountant at Kim & Chang. She practices primarily in transfer pricing, general tax consulting, and tax audit and dispute resolution.

Ms. Nam has been working as a tax attorney with the firm since the transfer pricing regime was first introduced to Korea in 1996. She focuses on international taxation and transfer pricing. Ms. Nam works on transfer pricing analysis and planning and representing clients in tax audits and disputes, including domestic tax appeals and Mutual Agreement Procedures (MAP) between Korea and tax treaty partner countries. Her key areas of expertise include filing and negotiations on the Advance Pricing Agreements (APA) with tax authorities.

With a wide range of industry knowledge from practicing in an accounting firm and an international finance division in an investment securities company, Ms. Nam was involved in Korea's first successful bilateral/unilateral APAs. As a leading member of the firm’s transfer pricing practice, she has successfully advised on more than hundred APAs/MAPs for clients in major industries including pharmaceuticals, IT, automobiles and parts, consumer goods, fashion and boutiques, chemicals, motion pictures and finance, such as banking, securities and private equity funds.

Prior to joining the firm, Ms. Nam worked for Arthur Andersen Co. in Seoul from 1992 to 1995 and for one of the leading investment securities companies in Korea from 1995 to 1996. In 2002, she also worked in the International Bureau of Fiscal Documentation (IBFD) in Amsterdam, as a research associate focusing on Korean transfer pricing and APAs.

Ms. Nam has published her work in various transfer pricing related publications, including "Transfer Pricing in Korea" (IBFD). She has been honored by the Minister of Strategy and Finance for her expertise in 2009. She has been a frequent lecturer for transfer pricing related subjects at the National Tax Officials Training Institutes since 2008.

Ms. Nam received a Master of Professional Accounting specialized in Tax from the School of Business Administration, University of Washington, Seattle in 2002 and a B.A. from the College of Business and Economy, Dongguk University in 1989. She is a certified public accountant of Korea.






    International Bureau of Fiscal Documentation (2002-2003)

    Kim & Chang (1996-Present)

    International Finance Division, Ssangyong Investment Securities Co., Ltd. (1995-1996)

    Arthur Andersen Co., Seoul (Anjin Accounting Corporation) (1992-1995)






APA/MAP
 
  •   Korea’s first bilateral APA for tangible goods transaction between Korea and US. 
  •   Korea’s first unilateral APA for royalty transaction between Korea and US. 
  •   Bilateral APA for the world’s largest semiconductor company. 
  •   Bilateral APA/MAP for world’s leading construction equipment company. 
  •   Korea-US MAP for transfer pricing of tangible goods, royalty, commission and service transactions for world’s leading chemical company. 
  •   Unilateral APA for a global leading investment bank for global trading and other banking transactions. 
  •   Unilateral APA for global pharmaceutical company. 
  •   Unilateral APA for world’s leading medical device company. 
  •   Unilateral APA for world’s largest IT storage company. 
  •   Korea-China Bilateral APA/MAP for Korea’s largest construction equipment company. 
  •   Korea-China Bilateral APA/MAP for Korea’s leading electronic company. 
 
Tax Audit Defense and Dispute Resolution
 
  •   Various tax audit defense projects for a broad spectrum of clients in the chemical industry, automobile and parts industry, semiconductor industry, fashion, boutique and cosmetics industry, electronics and IT industry, pharmaceutical industry, banking and securities industry, insurance industry, private equity funds, etc. 
  •   Various dispute resolution projects for clients through all level of tax appeal procedures and MAP especially for transfer pricing and international tax issues. 
 
Transfer Pricing Planning and Analysis
 
  •   Global transfer pricing policy set-up project for a client in the machinery industry for a Korean parent company and offshore subsidiaries. 
  •   Transfer pricing set-up project for a client in the consumer industry based on business restructuring. 
  •   Transfer pricing analysis and consulting projects for a broad spectrum of clients including a global mobile device manufacturer, a medical instrument and device distributor, a pharmaceuticals company, a telecommunication equipment company, an asset management service provider, a bank with brokerage, capital market service, M&A advisory service and other banking services, private equity funds, and an insurance company. 
 
Customs Valuation and Customs Audit Defense
 
  •   Advance Customs Valuation Approval (ACVA) projects for a client in the cosmetics industry. 
  •   Consulting projects on transfer pricing and customs valuation for clients in various industries including the pharmaceutical industry.





Awards

  •   Transfer Pricing Lawyer of the Year, Asia Women in Business Law Awards (Euromoney, 2021-2022)
  •   Leading Practitioner, Who’s Who Legal: Korea, Corporate Tax (Who’s Who Legal, 2021, 2023)
  •   Leading Practitioner, Expert Guides - Women in Business Law: Transfer Pricing (Expert Guides, 2020-2022)
  •   Highly Regarded, World Tax: Korea, Tax (International Tax Review, 2020)
  •   Highly Regarded, World Transfer Pricing: Korea, Transfer Pricing (International Tax Review, 2020)
  •   Leading Individual, The Legal 500 Asia Pacific: Tax (Legalease, 2019-2024)
  •   Best in Transfer Pricing, Asia Women in Business Law Awards (Euromoney, 2015, 2018)
  •   Leading Individual, Chambers Asia-Pacific, Tax: Consultants (Chambers and Partners, 2014-2024)
  •   Citation from the Minister of Strategy and Finance (2009.3.)

Publications/Activities

  •   Transfer Pricing and Customs Valuation - A Korean Perspective, International Transfer Pricing Journal Vol.28 No.4 (Co-author, IBFD, 2021) 
  •   Getting the Deal Through - Transfer Pricing: Korea chapter (Co-author, Law Business Research, 2018) 
  •   Asian Voices: BEPS and Beyond - Korea chapter (Co-author, IBFD, 2017) 
  •   Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies - Korea chapter (Co-author, Wolters Kluwer Law & Business, 2014) 
  •   Transfer Pricing in Korea for the Tax Treatment of Transfer Pricing (Co-author, IBFD, 2008) 
  •   Thin Capitalization: South Korea, Asia-Pacific Tax Bulletin Vol.11 No.5 (Co-author, IBFD, 2005) 
  •   Transfer Pricing in Korea: the APA experience, Asia Transfer Pricing (Co-author, International Tax Review, 2004) 
  •   Advance Pricing Approvals, Asia-Pacific Tax Bulletin Vol.9 No.7 (Co-author, IBFD, 2003)





Education

    School of Business Administration, University of Washington, Seattle (Master of Professional Accounting specialized in Tax, 2002)

    College of Business and Economy, Dongguk University (B.A., Accounting, 1989)


Qualifications

    Certified Public Accountant, Korea, 1992


Languages
  •    Korean and English





Tax ,  Transfer Pricing ,  Tax Audit & Tax Dispute Resolution