South Korea


Practice area

World TP Reviews

Transfer pricing
Deloitte Anjin

Seoung Kwon Song and Yong Chan Lee are key transfer pricing practitioners at Deloitte Anjin. Song worked with the National Tax service for 28 years, gaining experience in transfer pricing, tax audits, collections and appeals. The team provides practice covering APAs, BEPS documentation, audit defence and competent authority for MAPs and APAs. In the last two years, it won more than 120 BEPS cases for multinationals headquartered in Korea, including in the automotive, semi-conductor and chemical industries. 

Chris In helped a client on a tax audit matter related to an operating margin issue. It saved around $6.3 million. In this case, the team analysed the Chinese market and conducted many interviews in order to gain a better understanding

Kim & Chang

Dong Jun Yeo and Tae Yeon Nam are two key practitioners at Kim & Chang. The firm has the largest transfer pricing practice among law firms in South Korea. Its practice covers transfer pricing studies, APAs, the equivalent of an APA on the customs side and MAPs. Recently, it was active with bilateral APA, MAP and tax audit defense matters. 

In the last year, the team helped a client from the consumer goods area on a bilateral APA matter. In this case, the team provided services in the preparation, filing and conclusion of an APA renewal case. 

Client feedback 

“Professional knowledge.” 

Lee & Ko

Ted Kim leads transfer pricing practice at Lee & Ko. He has 26 years of experience in international tax and transfer pricing practice. Its practice covers transfer pricing tax defense, consulting and appeal. It has represented local clients in ASEAN countries such as Indonesia, Vietnam and China on APAs, MAPs, documentation and litigation matters. 

Steve Minhoon Kim joined the firm as a transfer pricing professional. He has more than 10 years’ experience in the Big Four and another law firm in Korea. He specialises in APA/MAP, documentation, planning and due diligence.  

Samil PwC

Samil PwC has a leading transfer pricing practice in South Korea in terms of the number of transfer pricing professionals and the diversity of engagements. The practitioners have a wide range of backgrounds including accounting, tax, finance, economics and law. Its practice includes APAs, mutual agreement procedures and dealing with difficult disputes. In addition, it provides advice dealing with recent trends such as guarantee fees and brand valuation. The firm has been selected by Korean conglomerates as the main choice for addressing BEPS requirements. 

The team is helping the Lotte Corporation on a transfer pricing matter by providing global license structure advice, valuation of arm’s-length royalty rates, and withholding tax, VAT and local restrictions advice. It also represents the Hyundai Motor Company and Kia Motors Corporation regarding MAPs and bilateral APAs issues. 

Yoon & Yang

Wankyu Jeon and Tae Hyoung Kim are the two key practitioners at Yoon & Yang. Its practices includes transfer pricing documentation and risk analysis. The team works with other practice groups such as corporate general, antitrust and competition, criminal law, international trade and intellectual property in order to meet clients’ needs. 

In 2018, Wankyu Jeon and Tae Hyoung Kim led the team assisting LEONI Wiring Systems Korea with the preparation of transfer pricing documentation related to the OECD’s BEPS action plan. This case had been valued at around $36 million. The team understood the client’s business operation, industry and transfer pricing policy so as to prepare the documentation.  

The firm recently hired 11 practitioners include customs attorneys, CPAs, expert advisors, partners and certified tax accountants. Ju-Hwang Lee, Sung Koo Cho and Yong Tae Kim left the firm during the research period. 

Client feedback 

“Yoon &Yang has a high professionality in the field of tax and is good at customer relationships.” 


Yong Whan Choi, Dong Hoon Ha and Young Suk Oh are the three key practitioners at Yulchon. The team currently has nine practitioners overall. Its practices include transfer pricing litigation and refunds, APAs, audit defence and advanced customs valuation arrangements (ACVAs). It helps clients with both inbound and outbound transfer pricing advice. In addition, it also provides services by considering the OECD guidelines, Korean tax law, the approaches of the Korean tax authority and current industry practices. 

In 2018, the team represented a Singapore-based multinational firm on the preparation of Korean transfer pricing policy. It provided advice concerning the use of intangible assets, container leases and the provision of support services. 

The firm recently hired some professionals to improve transfer pricing practice. Dong Hoon Ha, who once worked at EY, joined the firm in 2018. Joon Heon Lee, a former judge at Korean court, joined the firm as an attorney in 2019.