Transfer Pricing 2026

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

Sung Hyun Ryu draws on extensive knowledge and practical experience gained during his tenure as a deputy director at the National Tax Service, focusing his practice on tax advisory, tax controversy, and international taxation. He represents clients throughout all stages of tax dispute proceedings, including pre- assessment reviews, objections, tax audits, administrative appeals, and litigation. His experience includes domestic and international tax disputes involving value-added tax, comprehensive income tax, corporate tax, gift and inheritance tax assessments, and refund denials, as well as treaty- based disputes concerning beneficial ownership and the characterisation of patent royalty income under the Korea–US tax treaty.

Young Woong Park is a partner at Yoon & Yang and is licensed as an attorney, certified public accountant, and tax accountant. His practice focuses on tax litigation and controversy, tax audits, cross-border

M&A tax matters, tax planning, and overseas legislative advisory work. He advises domestic and multinational clients on complex tax issues, including criminal tax defence, challenges to corporate, income, gift, consumption, and local tax assessments, correction claims, and matters involving OECD Pillars, US tax legislation, intercompany royalties, digital assets, real estate and trust taxation, cross-border restructurings, and US bankruptcy-related tax issues. Prior to joining the firm, he served on the international tax team at Samil PricewaterhouseCoopers (Samil PwC).

Yoon & Yang LLC Floors 6, 17, 18, 19, 22, 23, 27 & 34, ASEM Tower 517 Yeongdong-daero Gangnam-gu Seoul

South Korea 06164 Tel: +82 2 6003 7000 Fax: +82 2 6003 7800 Email: yoonyang@yoonyang.com Web: www.yoonyang.com

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