Transfer Pricing 2026

SOUTH KOREA Trends and Developments

Trends and Developments Contributed by: Dong Shin Lee, Wankyu Jeon, Sung Hyun Ryu and Young Woong Park Yoon & Yang LLC

Yoon & Yang LLC has a tax practice group comprised of a multidisciplinary team of attorneys, certified pub - lic accountants, tax advisers and customs special - ists who combine technical excellence with practical experience. The group provides proactive and com - mercially focused tax strategies across a wide range of matters, including M&A, corporate restructurings, financial transactions, cross-border investments, in - ternational transactions and succession planning, while also offering comprehensive post-assessment support through administrative appeals, tax litigation, criminal defence and constitutional challenges to tax legislation. At the core of the practice, the Interna - tional Tax Strategy Center delivers integrated advi -

sory services on complex cross-border tax issues in an increasingly sophisticated regulatory environ - ment. The team advises on international tax structur - ing, transfer pricing, BEPS initiatives and the Global Minimum Tax under Pillar Two, and represents clients in transfer pricing disputes, APA and MAP proceed - ings, treaty interpretation and beneficial ownership controversies. Working closely with corporate and finance practitioners, the group provides seamless, end-to-end support to multinational enterprises and foreign-invested companies, ensuring technically rig - orous and commercially pragmatic solutions aligned with global business objectives.

Authors

Dong Shin Lee is a distinguished former tax official and renowned

Wankyu Jeon serves as Head of the Tax Practice Group. His practice focuses on international taxation, corporate and individual income tax, value-added tax, transfer pricing, and related tax advisory and controversy

practitioner in Korean tax field, having served in various positions including Director General for Property Taxation Bureau of the National Tax Service (NTS) and Commissioner of NTS Daejeon and Busan Regional Office. During nearly three decades in public service, Dong Shin developed deep expertise in tax law and extensive practical experience, notably in tax audits, international tax investigations, and property taxation, including inheritance and gift tax matters. Dong Shin joined Yoon & Yang in 2023 as a senior advisor, dedicating his expertise to tax advisory services.

matters. He has been recognised as a Chambers- ranked leading lawyer in tax since 2022. Wankyu has established a strong track record in complex tax litigation and regularly advises major multinational corporations and leading Korean conglomerates, including Hyundai E&C, Daewoo E&C, and Rolex Korea. He also serves as a director of the International Fiscal Association (IFA) Korea.

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