International Tax Services
With Seohyun's accumulated experience, we will provide clear solutions to your international tax issues!
International Tax Services
Introduction to International Tax Services
1. Overview of International Tax Services
Our country has grown into a strong trading nation due to policies that consistently promote exports. From a tax perspective, this inevitably leads to issues of double taxation imposed by multiple countries. Such double taxation significantly increases the costs for companies.
Recently, the G20 and OECD have been introducing various new systems to prevent tax avoidance behaviors, such as BEPS (Base Erosion and Profit Shifting). As part of this effort, our country has introduced documentation for transfer pricing since 2016.
Governments' BEPS countermeasures, including transfer pricing documentation, require companies to provide extensive information on overseas investments, foreign affiliates, financial information, global business activities, and transactions with overseas related parties. Companies need to invest considerable time and effort to provide this information.
Unlike domestic tax issues, international tax issues cannot be resolved solely with knowledge of domestic tax laws. They require a broad understanding of the tax laws of the source country and tax treaties. Therefore, it is extremely challenging for companies to handle international tax issues on their own.
Seohyun provides premium, specialized international tax services with a team of experts including foreign accountants and certified public accountants, led by a tax advisor recognized for their expertise in international and Chinese taxation.
2. Process of International Tax Services
To provide optimal services to our clients, Seohyun follows the process below
- -Consultation with clients (to identify the optimal service tailored to the client's situation)
- -Identification of tax issues (preliminary review of the company’s organization, business activities, financial status, etc.)
- -Development of solutions to address the issues (solutions to minimize tax risks)
- -Provision of solutions to clients
- -Response to related authorities (representing clients in addressing issues with related authorities, if necessary)
Detailed Services of International Tax Services
BEPS
Our country has incorporated the BEPS project's Actions 8-10 into the law regarding international tax adjustments. Taxpayers meeting certain criteria in terms of the scale of international transactions with foreign related parties and their sales revenue are required to submit integrated reports on international transactions (master file, local file, and country-by-country report). Seohyun provides services to prepare these reports, reflecting the transaction types and industry characteristics to minimize transfer pricing tax risks.
International Tax Advisory
International transactions with overseas affiliates are almost essential for large corporations, medium-sized enterprises, and even small businesses. Companies that do not conduct these transactions at arm’s length are exposed to transfer pricing tax risks. Seohyun offers advisory services to establish transfer pricing policies to eliminate these risks, allowing companies to focus on their business.
- Advisory services on permanent establishment taxation issues
- Advisory services on taxation issues for expatriates
- Advisory services on withholding tax issues for interest, dividend, royalty, and capital gains
- Other international tax advisory services
Transfer Pricing Audit Assistance
During transfer pricing audits, companies often face challenges due to extensive requests for internal information by tax authorities, difficulties in accessing commercial databases, and verifying the arm’s length price proposed by the tax authorities. It is challenging for companies to handle these audits without the assistance of external transfer pricing experts. Seohyun provides audit assistance services with a dedicated team led by experienced tax advisors who have conducted transfer pricing audits at the National Tax Service to ensure companies are not subject to unfair transfer pricing taxation.
Major Performance
- Provided integrated report preparation services for international transactions (CBCR, Master file, Local file) for large company A
- Successfully filed a correction request by analyzing the transfer pricing of processing service transactions between listed company B and its overseas subsidiary
- Provided transfer pricing advisory services to prevent tax imposition during audits of transactions between large metal manufacturer C and foreign related companies
- Provided transfer pricing advisory services to prevent tax imposition during audits of royalty transactions between foreign apparel company D and its foreign affiliates
- Provided transfer pricing advisory services to prevent tax imposition during audits of software development service fees paid by large company E to its overseas research center
- Provided transfer pricing advisory services to prevent tax imposition during audits of non-listed foreign stock transactions between game company F and its foreign affiliates
- Provided transfer pricing advisory services to prevent tax imposition during audits of drug transactions between large pharmaceutical company G and its foreign affiliates
- Provided international tax advisory services to prevent tax imposition during audits of beneficial ownership for large company H
- Provided advisory services on whether the overseas subsidiary of large company I had a substantial place of management in Korea to prevent tax imposition during audits
