International Tax
We develop tax strategies from a global perspective
on international tax issues including transfer pricing, tax treaties, and overseas investment structures.
Overview
International tax encompasses tax issues arising from cross-border economic activities, including transfer pricing regulations, interpretation and application of tax treaties, foreign tax credits, overseas investment structure planning, and BEPS (Base Erosion and Profit Shifting) compliance. Complex analysis at the intersection of OECD guidelines and the domestic tax laws of each jurisdiction is essential.
PYEONG AN's team of specialists with National Tax Service international tax division backgrounds and attorneys with extensive cross-border transaction advisory experience provides comprehensive support to multinational corporations, including transfer pricing documentation (Master File, Local File, CbCR), advisory on treaty-based tax exemptions and reductions, and tax structure design for overseas entity establishment and investment.
Key Practice Areas
- Transfer pricing advisory and documentation
- Tax treaty interpretation and application advisory
- Foreign tax credit and indirect foreign tax credit review
- Overseas investment structure design (holding companies, SPCs, etc.)
- BEPS (Base Erosion and Profit Shifting) compliance advisory
- Mutual Agreement Procedure (MAP) and Advance Pricing Agreement (APA) representation