Tax Litigation
In tax litigation before the Administrative Court, High Courts, and the Supreme Court,
we precisely challenge the illegality of tax assessments to reduce our clients' tax burden.
Overview
Tax litigation encompasses all judicial proceedings related to taxation — including revocation actions against tax assessments, unjust enrichment claims for tax refunds, and civil litigation involving tax claims. Success requires both sophisticated legal analysis of the interpretation and application of tax law, and the design of persuasive arguments that will convince the court.
PYEONG AN operates as a seamless trinity of former judges with specialist tax court experience, NTS-background tax specialists, and dedicated tax litigation attorneys. By combining an understanding of the court's judgment criteria with empirical materials capable of rebutting the tax authority's administrative practices, we maintain a high success rate.
We demonstrate differentiated litigation capability in the most demanding cases — Supreme Court en banc proceedings, revocation actions involving corporate income tax and capital gains tax in the hundreds of billions of won, and complex litigation incorporating international tax issues.
Key Practice Areas
- Revocation actions against tax assessments (corporate income tax, income tax, VAT, inheritance tax, gift tax)
- Unjust enrichment claims for tax refunds
- Civil litigation involving tax claims (fraudulent conveyance actions, etc.)
- Specialist representation in Supreme Court appeals
- International tax litigation (transfer pricing and tax treaty interpretation)
- Real estate tax litigation (capital gains tax and comprehensive real estate holding tax)