Seong Kwon Song is the head of the transfer pricing team at Deloitte Anjin. Song worked with the National Tax Service for 28 years, gaining extensive experience in transfer pricing, tax audit, collection and appeals. The transfer pricing team assists clients with APAs, BEPS documentation, audit defence and competent authority for MAPs and APAs. Deloitte Anjin also won more BEPS cases for multinationals headquartered in Korea between 2016 and 2017, including in the automobile, semi-conductor and chemical industries.
In 2017, Yong Chan Lee, partner of Deloitte Anjin, assisted a Korean distributor with audit defence in relation to a permanent establishment issue. Yong Hoon Nam, partner of Deloitte Anjin, advised a marine power engines manufacturer with a working capital adjustment deal at tax tribunal.
Kim & Chang has the largest transfer pricing practice among law firms in South Korea. The team provides a full range of transfer pricing services, including transfer pricing studies, APAs, the equivalent of an APA on the customs side and MAPs. The firm’s tax practice features more than 100 attorneys and CPAs.
In recent matters, the team dealt with two MAPs cases. One was the case of a MAP between Korea and the US valued at around $42.6 million, the other one was tax audit defence followed by MAP between South Korea and Switzerland. The team also advised one client on tax audit defence, which valued at around $85 million.
Samil PwC is the leading transfer pricing firm in Korea, based on the number of transfer pricing professionals and the diversity of engagements. The transfer pricing team comes from various background, including accounting, tax, finance, economics and law. The firm also hires advisers who have previously served with the National Tax Service and other government bodies. The firm specialises in APAs, mutual agreement procedures and dealing with difficult disputes. The transfer pricing team also provides services that address recent trends such as guarantee fees and brand valuation. Korean conglomerates select Samil PwC as the main choice for addressing BEPS requirements.
In 2017, Junghwan Cho helped one of Korea’s leading global steel companies support a bilateral APA request between Korea and Thailand. Samil PwC prepared the economic analysis underlying the APA request and completed application. The successful result helped the client eliminate a significant amount of potential double taxation risk.
In 2017, professional Seung-Nok Baek helped one client advise on BEPS documentation, including the review of global transfer pricing policy and tax appeal for guarantee fees.
Dong Soo Kim and Seok Hong Kang are the leaders of the transfer pricing practice at Yulchon. The transfer pricing team provide services involving litigation, transfer pricing refunds, audit defence and advanced customs valuation arrangement (ACVA).
The transfer pricing team helped major multinationals address guarantee fee case. This included groups like Hyundia Motors, Kia Motors, LG Group and CJ Group, with the deal valued at $260 million. The team persuaded the court to recognise that the taxpayer’s arm’s length calculation method was correct. Dong Soo Kim and Hyung Bae Kim represented Burberry in a matter of concerning ACVA application and renewal. The firm found the connection between the transfer pricing valuation method and the customs valuation method, reducing Burberry’s customs and value added tax-related risks through ACVA.
The transfer pricing team has expanded with the addition of Dong Hoon Ha, Dong Hun Lee and Na Ree Kim who worked at EY HanYoung transfer pricing team as an experienced TP experts.