While Lee and Li provides a full range of tax services including tax planning, dispute resolution, and tax structuring, tax disputes have been a large focus of the firm's attention. The tax practice comprises eight partners and 34 fee earners, and is ...
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While Lee and Li provides a full range of tax services including tax planning, dispute resolution, and tax structuring, tax disputes have been a large focus of the firm's attention. The tax practice comprises eight partners and 34 fee earners, and is led by Frank Lin and Josephine Peng. Lin is recommended by peers for his M&A work.
Lin represented a multinational company in a dispute involving the validity of a tax assessment of its liquidated affiliate in Taiwan, and whether the liquidated company should be subject to additional income tax. After three years, the Ministry of Finance ruled that the company was legally liquidated and that the tax authorities' decision should be revoked. The case is now being reassessed by the tax authorities.
Peng is representing an international company's Taiwanese branch in a transfer pricing audit on its income tax return. The Ministry of Finance is considering applying the thin capitalisation rules or challenging the necessity of offshore affiliate loans, to disallow a portion of the interest expense. Peng and her team are preparing documents to prove that the loans are necessary and that the thin capitalisation rules should not apply.
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