[Transfer Pricing]

• Successfully defended a U.S.-based OLED materials company in a transfer pricing tax audit.

• Successfully defended a U.S.-based food franchise company in a transfer pricing tax audit.

• Successfully defended a U.S.-based life insurance company in a transfer pricing tax audit.

• Successfully defended a U.S.-based game development company in a transfer pricing tax audit.

• Provided advisory services on global transfer pricing policy development for major conglomerates across various industries in Korea.

• Represented a footwear manufacturer in a bilateral Advance Pricing Agreement (APA) negotiation between the Directorate General of Taxes (DGT) of Indonesia and the National Tax Service (NTS) of Korea.

• Represented a Korean trading company in a bilateral APA negotiation between the Directorate General of Taxes (DGT) of Indonesia and the National Tax Service (NTS) of Korea.

• Represented a Korean furniture manufacturing company in a bilateral APA negotiation between the Directorate General of Taxes (DGT) of Indonesia and the National Tax Service (NTS) of Korea.

• Represented a Korean manufacturing company in an APA and Mutual Agreement Procedure (MAP) negotiation between the Canada Revenue Agency (CRA) and the National Tax Service (NTS) of Korea.

• Represented a German automobile manufacturer in a bilateral APA negotiation between the German Federal Central Tax Office (BzSt) and the National Tax Service (NTS) of Korea.

• Advised Korean corporations on handling overseas transfer pricing tax audits and litigation support.

• Prepared transfer pricing documentation, including BEPS Local File, Master File, and Country-by-Country (CbC) Reporting, for domestic and foreign-invested corporations.

• Provided advisory services on transfer pricing policy development related to management service fees and their deductibility for Korean and foreign-invested enterprises.

• Conducted transfer pricing policy assessments and prepared reports on the arm’s length pricing of guarantee fees for major Korean conglomerates.

[Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)]

• Advised foreign-invested enterprises on domestic tax and international tax issues, including corporate income tax, individual income tax, VAT, and tax credits.

• Provided advisory services on permanent establishment (PE) risks and transfer pricing issues related to the incorporation of foreign-invested entities in Korea.

• Assisted foreign-invested enterprises in evaluating unlisted stock valuations under the Inheritance and Gift Tax Act and the Income Tax Act in relation to restructuring and governance changes.

• Advised foreign-invested enterprises on tax implications related to corporate restructuring, including mergers and acquisitions.

• Represented foreign-invested enterprises in withholding tax exemption or reduced withholding tax rate applications under tax treaties.

• Tax due diligence work for a contemplated acquisition of a target in Korea or related tax insurance underwriting support

• Prepared transfer pricing reports to determine arm’s length price in domestic related-party transactions governed by the Korean Corporate Income Tax Act.

• Provided advisory services and litigation support on income characterization (e.g., business income vs. royalty income) and beneficial / substantial ownership issues for foreign-invested enterprises.

[Outbound Tax Advisory (Overseas Investment Tax Services)]

• Provided tax structuring advice for Korean corporations investing overseas or establishing foreign subsidiaries, including assessments of tax risks related to VAT, permanent establishments, transfer pricing, corporate tax, and withholding tax in the target jurisdiction.

• Advised domestic investment funds on tax implications related to overseas real estate investments.

• Assisted Korean corporations in managing and responding to tax litigation in foreign jurisdictions.

• [Publications and Contributions]
• Transfer Pricing Guide – Korean Chapter, Chambers & Partners, since 2021
• Global Practice Guides: Tax Controversy – Q&A: South Korea, Chambers & Partners, since 2024
• Korean Chapter of Transfer Pricing, Lexology Getting The Deal Through (GTDT), August 2023
• South Korea First to Enact Global Minimum Tax Rules Amid Concerns, Bloomberg Tax, July 2023
• The Corporate Tax Planning Law Review, The Law Review, May 2023
• Distinctive Feature of South Korea’s Regulation and Local Practice Concerning Attribution of Profits to Permanent Establishment, Tax Expert Guide – CorporateLiveWire, November 2022
• Intercompany Loan Transaction: Recent Developments in South Korea’s Transfer Pricing Regime, Bloomberg Tax, February 20, 2022
• South Korea – Trend in Transfer Pricing, Bloomberg Tax, November 16, 2020
• South Korea – Trend in Permanent Establishment, Bloomberg Tax, October 21, 2020
• New South Korea Transfer Pricing and Diverted Profit Tax Laws Enter into Effect, MNE Tax, April 16, 2020
• Korean Tax Law Adopts New Simplified Transfer Pricing Rules Relating to Low Value-Adding Intra-Group Services
• [Speaking Engagements and Panel Participation]
• Moderator, 2026 AMCHAM Korea Taxation Committee Meeting on 2026 tax law amendment
• Panelist, The 2025 IFA Indonesia Annual International Tax Seminar - session 2, December 3, 2025
• Panelist, Transfer Pricing Defense update for Tax and TP Executives in Asia Pacific hosted by WTSTaxise, April 9, 2025
• Moderator, First Joint IFA Seminar/Webinar hosted by IFA Korea and IFA U.S. Southern California on the topic: “Navigating U.S. and International Tax Policy: Key Considerations for Korean and U.S. Investors”
• Speaker, IFA Hong Kong 2024 Asia Pacific Regional Tax Conference, April 22, 2024
• Panelist, “Transfer Pricing Implications of Pillar One” – First session of the Monthly International Tax Forum, hosted by IFA Korea, November 2023
• Presenter, OECD Korea Policy Centre – “Transfer Pricing of Financial Transactions”, January 2022
• Panelist, IFA Korea Tax Webinar, Session 4 – Impact of COVID-19 on Transfer Pricing
• [Academic and Government Lecture]
• Lecturer, International Tax and Transfer Pricing – Zakat, Tax and Customs Authority (ZATCA), Saudi Arabia, October 2023
• Lecturer, Transfer Pricing – Korean Customs Service (KCS)
• Lecturer, Transfer Pricing – The Graduate School of Science in Taxation (GSST), University of Seoul