Yoon & Yang LLC

International Tax Strategy Center

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Yoon & Yang LLC’s International Tax Strategy Center provides comprehensive professional services to help companies address complex international tax issues arising in a rapidly changing global business environment. Our services span a broad range of areas, including international tax advisory and diagnostic reviews, responses to tax audits, tax appeals and objections, tax litigation, and customs matters.

The Center advises not only on tax strategies, restructurings, and new investment matters for corporations, but also on tax planning for business succession and inheritance/gifts, and on tax and legislative issues relating to emerging topics such as virtual assets (cryptocurrencies). In particular, in the field of international taxation, we deliver sophisticated solutions for advanced issues such as the BEPS project, transfer pricing, APA/MAP procedures, and the Global Minimum Tax (Pillar Two), supporting outbound investments by Korean companies as well as inbound investments by foreign companies into Korea.

The International Tax Strategy Center is comprised of leading professionals across tax advisory, international tax, corporate support, tax audits, tax disputes, and customs. We protect our clients’ assets and businesses, and through close collaboration with professionals in related practice groups—such as the Corporate Advisory Group and the Finance Group—we provide a best-in-class one-stop service covering the full business lifecycle, from establishment to operations, financial closing, and ongoing tax risk management.

▶ Introduction Video – International Tax Strategy Center

Key Services

International tax advisory on Korean companies’ outbound matters, including the establishment of overseas branches/subsidiaries, corporate restructurings, and overseas investments
International tax, customs, and foreign exchange advisory on foreign companies’ investments into Korea and exit/withdrawal from Korea
Transfer pricing services, including TP policy design, TP documentation, and defense in TP disputes
Pre-implementation impact assessments and response strategy planning for the introduction of the Global Minimum Tax (Pillar Two)
Advisory on legislative, regulatory, and policy developments relating to the BEPS project and international taxation
Tax appeals/objections and tax litigation relating to outbound and inbound transactions
Pre-audit tax compliance reviews and tax audit defense for multinational companies and foreign-invested enterprises
Managing criminal risk arising in connection with international tax and transfer pricing issues
Tax advisory for Korean tax residents regarding emigration and overseas asset investments
Payroll services and tax advisory relating to employees dispatched/seconded overseas (expatriates)

Representative Cases

Represented a foreign company in litigation concerning whether patent royalty income received from a Korean company constituted Korea-source income
Represented a foreign company in litigation concerning whether income received from a Korean company qualified as business income exempt from Korean withholding tax
Represented a foreign company receiving royalty income from a Korean company in litigation concerning whether it qualified as the beneficial owner of such income and was therefore entitled to treaty benefits under the Korea–Ireland tax treaty
Represented a foreign company in litigation concerning whether service fees received from its Korean subsidiary fell outside the arm’s length range
Conducted domestic and cross-border transfer pricing tax risk assessments for intercompany transactions with overseas related parties carried out by a Korean company in connection with its overseas business
Provided legal and tax advice on outbound investments by Korean companies
Provided legal and tax advice on inbound investments by foreign companies into Korea
Prepared and advised on integrated reports on international transaction information and transfer pricing “local file/master file” (and related) documentation
Advised on APA and MAP procedures to prevent and resolve international double taxation
Advised on tax-efficient planning related to emigration
Advised on virtual asset (cryptocurrency) matters
Advised on BEP-related matters, including the Global Minimum Tax (Pillar Two)