Dear Clients and Friends of Shin & Kim LLC,

To help global businesses navigate the rapidly evolving regulatory landscape of international taxation, transfer pricing, customs, and foreign exchange, Shin & Kim’s Tax Group is pleased to announce the launch of the Global Tax Center and its newsletter, the Global Tax Brief.

Led by Managing Partner Je-Heum Baik, Head of the Global Tax Center, and Foreign Attorney Maria Chang, Deputy Head of the Global Tax Center, our team of seasoned cross-border professionals leverages deep practical experience to help multinational enterprises proactively mitigate legal risks and manage complex disputes.

The Global Tax Brief will provide timely regulatory updates and actionable insights to support your strategic decision-making and sustainable growth. Thank you for your continued trust and support.

 

1. Case Law

▶ Special Relationship Found Between Affiliated Foreign Corporations Located in the Same Jurisdiction for Purposes of Korea’s Constructive Dividend Rules
▶ Dividends Attributable to Additional Shares Acquired After Tax Incentive Approval Deemed Ineligible for Tax Exemption Under the Restriction of Special Taxation Act
▶ Supreme Court Confirms Application of Increased Korea–Australia FTA Preferential Tariff Rate Based on Vessel Arrival Date Where Pre-Arrival Import Declaration Was Prohibited
▶ Court Recognizes Irish Regional Hub as Beneficial Owner and Substantive Owner of Korean Software Royalties Under the Korea–Ireland Tax Treaty
▶ Court Rejects Permanent Establishment Status for Korean Affiliate Providing Marketing and Advertising Support to Foreign Platform Operator
▶ Supreme Court Clarifies Treaty Benefits for U.S. LLCs and Patent Transfer Proceeds Under the Korea–U.S. Tax Treaty

 

2. Legislative Updates

▶ New Administrative Penalties for Failure to Report the Status of Foreign Corporation Liaison Offices
▶ New Filing Obligation Relating to Treaty-Based Reduced Withholding Tax Rates
▶ Expansion of Korean-Source Other Income Rules for Transfers of Assets at Below-Market Value
▶ Clarification of the Scope of Korean-Source Dividend Income for Foreign Corporations
▶ EU Carbon Border Adjustment Mechanism (CBAM) Enters Definitive Phase
▶ Korea Customs Service Introduces Comprehensive Periodic Anti-Dumping Review System

 

3. Shin & Kim Tax Group Briefing 

▶ New Professionals Joining the Tax Group
▶ Recent Seminars