Kim & Chang operates with one of the largest tax practices within the Korean tax community. Key areas for the firm include transfer pricing, M&A, litigation and advance pricing agreements. This experience with APAs has provided the firm with a steady ...
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Kim & Chang operates with one of the largest tax practices within the Korean tax community. Key areas for the firm include transfer pricing, M&A, litigation and advance pricing agreements. This experience with APAs has provided the firm with a steady source of work over the past year. DJ Yeo and QH Lee represented a client in negotiating an APA between the US and Korean competent authorities. The pair managed to secure approvals from the tax authorities for the use of the transactional net margin method with regard to royalty paid on a software licence. This was the first time this method has been used in South Korea for a royalty licence.
Seven of the firm's tax professionals were involved in the successful appeal against the assessment of heavier registration tax on a client's acquisition of real property using a dormant company in a metropolitan area. The team argued that the tax authority's assessment of applying the substance-over-form principle was done without legitimate legal grounding.
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