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Sung-Soo Han

2012

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Full-Text Articles in Taxation-Transnational

The International Tax Bible - Management (Intra-Group) Service Fee Case, Sung-Soo Han Jan 2012

The International Tax Bible - Management (Intra-Group) Service Fee Case, Sung-Soo Han

Sung-Soo Han

This report was made for the purpose of discussion with the Korean tax authority during the tax audit period against a foreign subsidiary company doing business in Korea. This kind of tax audit defense approach was a new one at that time. This report was inserted in the book "the International Tax Bible(국제조세바이블)" which was published in January 2012. When this report was made, there was no specific rules concerning the "management service fee (intra-group service fee)" in the Korean Corporate Tax Law and thus there often took place the conflict between taxpayers and tax authorities with regard to the …

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The International Tax Bible - Treaty Shopping Case, Sung-Soo Han Jan 2012

The International Tax Bible - Treaty Shopping Case, Sung-Soo Han

Sung-Soo Han

This position paper was made for the purpose of discussion with the Korean tax authority during the tax audit period against a foreign subsidiary company doing business in Korea. This kind of tax audit defense approach was a new one at that time. This position paper was inserted in the book "the International Tax Bible(국제조세바이블)" which was published in January 2012. When this report was made, there was no specific rules concerning the "treaty shopping" in the Korean tax law and thus there often took place conflicts between taxpayers and tax authorities with regard to the appropriateness of treaty shopping. …

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The International Tax Bible - Transfer Pricing Case, Sung-Soo Han Jan 2012

The International Tax Bible - Transfer Pricing Case, Sung-Soo Han

Sung-Soo Han

This position paper was made for the purpose of discussion with the Korean tax authority during the tax audit period against a foreign subsidiary company doing business in Korea. This kind of tax audit defense approach was a new one at that time. The issue is the appropriateness of transfer pricing. This position paper was inserted in the book "the International Tax Bible(국제조세바이블)" which was published in January 2012.

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