South Korea

The team at Deloitte offers services covering tax controversy, global trade advisory and transfer pricing. As for their trade advisory group, it helps clients with customs audit and investigation assistance, remedies through customs appeals, FTA origin management consulting, customs and trade advisory services and transfer pricing consulting services. It has Japanese, Chinese and Korean service groups to expand its business market and meet clients’ needs. It provides specialised services for various sectors, including consumer and industrial products, energy and resources, financial services industry, life sciences and healthcare, the public sector and technology, media and telecoms.

The transfer pricing team led by Eun Jin Choi recently assisted an LCD manufacturer in a tax audit defence. The matter involved royalty payments from the Korean subsidiary to the US parent.

During the research period, the team further expanded by adding four new partners: Ji Hun Leem, Hyun Mo Goo, Cheol Kim and Kyung Jo Kim. Before joining Deloitte Anjin, Leem and Kyung Jo Kim worked at KPMG Samjong.

The dedicated transfer pricing team of EY Korea consists of 36 professionals, including four partners and three directors. It is experienced in handling BAPAs within different jurisdictions, assisting with transfer pricing audits and BEPS documentation. Partner In-Sik Jeong leads the transfer pricing practice. Another key partner is Yong-Hun Nam. Nam specialises in MAPs and APAs.

One recent example of the firm’s work saw it assisting a client in its transfer pricing planning. The project involved a new transfer pricing policy that covered both the client’s domestic and overseas intercompany transactions.

Seonghoon Jeon joined the team as a senior advisor from Yulchon during the research period.

Kim & Chang provides a full range of tax services, including tax planning, M&A, applications for tax exemptions, tax rulings, transfer pricing studies, APAs, advance customs value agreements, tax health checks, tax audit defence, tax appeals and litigation, MAPs and general advice on all Korean tax issues affecting a company from incorporation to exit.

The team led by John Kwak recently served as a legal counsel and represented the Ford Motor Company for the tax structuring of joint venture from a Korean tax perspective. The work included presenting various structuring options and preventing double taxation in both Korea and the US.

Client feedback

“Kim & Chang has a host of high-calibre professionals who can handle complex transfer pricing matters.”

“Knowledgeable team with great relationship and insight.”

“Proactive and forward-thinking mindset. Strategic approach using benchmarks across industries. Good communicator (local and headquarters).”

“K&C is not only a specialist in their field but also a very understanding and strategic partner, so a client can trust them and come up with a new business plan.”

“Kim & Chang provides excellent tactical and technical advice. Kim & Chang is able to provide insights on the likely actions of the taxing authority, our available options, and recommendations. Kim & Chang is consistent in their quality and commitment to client service.”

“High quality professionalism and network.”

“Very professional, good communication, depth of knowledge.”

“Relevant experience, networks, intel gathering.”

“Kim & Chang was able to explain our tax positions, which minimised any tax controversies with taxing authorities. Kim & Chang was able to manage course of audit and manage expectations of tax audit team which resulted in a favourable conclusion.”

“Thoughtful, thorough and responsive.”

“They came in in the midst of a tax audit when situation was not looking good but managed to play a mediating role between the company and the tax auditor in a very professional manner. Their level of support and expertise significantly helped to turn the tide around and enabled to settle the tax audit in a relatively successful way.”

“Ability to provide clear logic and solve problems.”

“Smooth response to tax disputes and feedback.”

“They present specific and reasonable arguments and explain sufficiently so that the company can understand.”

The Lee & Ko tax group is comprised of over 90 professionals. It offers tax services in areas of international tax and transfer pricing. Jay Shim, one of the most experienced foreign attorneys and international tax practitioners in Korea, leads the international tax practice. Ok Hyun Ma and Kyung Tae Kim co-head the tax team. They both focus their practice on tax litigation.

Details of the firm’s work and clients remain confidential.

Client feedback

“Very knowledgeable in complex tax laws and precedents.”

The team specialises in global tax services (inbound and outbound), transfer pricing, middle-market services, global mobility and business process outsourcing services, tax controversy and dispute resolution, private equity/M&A tax, family and business succession for wealthy individuals and private businesses and customs and international trade. The tax controversy and dispute resolution team consist of 40 former senior-ranking tax officials.

One recent example of the firm’s work saw it assisting a Korean business group specialised in healthcare and biologics in a petition for tax refund. The team led by Chaung-Hun Keum provided strategic advice and assistance throughout a series of proceedings of the petition. It assisted the client in obtaining a favourable decision resulting in a significant positive impact on future cash flows.

Tax specialist Chelju Son joined the team in 2023. The team added two new directors Hyejin Lee and Myungjin Lee during the research period. In the same space, partner Dong-Jin Nam and six other directors left the team.

KPMG Korea offers a range of services, including audit, tax and advisory services. It has strengths in sectors such as financial services, healthcare, consumers, industrial manufacturers and IT. Its global transfer pricing service team consists of 59 professionals. It supports clients by developing and implementing transfer pricing policies, providing BEPS documentation services, assisting in APA/MAP procedures, and assisting in tax audits and appeals. In addition, KPMG has a dedicated custom team for providing services including assisting with customs audits.

One case study showed that the team recently assisted a Korean subsidiary of a multinational life insurance company in local tax refund claims regarding acquisition tax reduction. The tax refunded through the claim was approximately ₩28.3 billion. The work included developing ideas, preparation of related data, explanation of rationale and communication with the relevant tax authorities.

HW Song joined the team from Kim & Chang as a partner during the research period. In addition, two directors, two principals and three senior managers also joined.

Je Heum Baik leads the tax group at Shin & Kim. It is comprised of tax lawyers, CPAs and tax accountants. Its practice covers tax litigation and administrative appeals, tax advice, tax investigation, and advisory services for foreign clients. It has the capability to offer accurate and innovative tax advice in transactional areas such as M&A, real estate, business succession, labour, financial and general corporate matters.

The team recently assisted Chubb Life Insurance Group with its US$5.75 billion acquisition of Cigna Korea. The work involved advising the client on the acquisition of Cigna Korea’s business across seven countries, where Korea made up 70% of the deal size.

Shin & Kim recently further expanded its practice by adding Je Heum Baik and Hanna Yi. Baik specialises in tax litigation and general tax consulting. Yi specialises in transfer pricing and international tax practices.

The team at Yoon & Yang consists of over 60 practitioners including partners, associates, foreign attorneys, CPAs, customs attorneys, certified tax accountants and expert advisors. Senior partner Wankyu Jeon leads the international tax team and transfer pricing team. Its practice covers tax litigation and disputes, customs and tax audits, general tax advice and tax compliance. Its clients include government, SMEs, large conglomerates and wealthy individuals.

Recent examples of the firm’s work have seen it handling various customs matters. The team assisted Hanwha Solutions Corporation in customs audit and foreign exchange audit. It also supported Hyundai Motors Company in reviewing customs issues related to fees for purchase agency services.

Senior counsel Moon Tae Byun joined the firm from Lee & Ko during the research period. The team also welcomed Chan Bin Park as a customs attorney to strengthen its customs practice.

Client feedback

“In-depth transfer pricing knowledge and experience in both US and KR TP laws and local. Strong professional attitude in terms of easy-to-understand explanation and timely communication.”

“I think the biggest advantage is the comprehensive and detailed work results on our requests, and also the sincere opinions, fully focused and listening to the attitude of experts in different fields are the best.”

The key practitioners at Yulchon are Yun Heui Cho and Kyu Dong Kim. Its practice covers international tax, due diligence, dispute resolution and litigation, and corporate tax. It also advises clients on M&A, inbound and outbound structuring, cutting-edge ruling requests, compliance, tax audit defence and tax appeals. Yulchon joined Taxand earlier as a new member in South Korea, which allows it to service clients with cross-border tax advice.

One recent example of the firm’s work saw it successfully represent Samsung SDS in a lawsuit seeking the cancellation of a ₩149 billion corporate income tax assessment. The tax refund involved ₩149 billion.

The team recently welcomed Ho Youn Cho, Chang Bo Ko and Jin Sung Kim as new tax partners.

Client feedback

“Yulchon is really awesome because they are always trying to solve our issue.”