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Practice Area|Tax

Tax Disputes

Recently, tax authorities tend to interpret tax laws more proactively than ever before. Unlawful taxation disposition infringes on the property rights of clients, which should be cancelled, changed, or invalidated through appeal procedures under the law. Jipyong, through a professional team of experienced tax attorneys and certified public accountants, represents clients in lawsuits claiming for cancellation of illegal taxation dispositions to resolve the illegality.

Key Practice Areas Close

    • Request for rectification
    • Cancellation of the refusal of request for rectification
    • Pre-deliberation review
    • National and local tax complaints and requests for deliberation
    • Requests for review by the Board of Audit and Inspection
    • National and local tax appeals
    • Cancellation of taxation and confirmation of the invalidity of taxation
    • Tax refund
    • Appeal for unconstitutional tax laws to the Constitutional Court

Experience Close

    • Represented a lawsuit for cancellation of donation tax imposition which is unlawful due to the application of duplicate provisions on gift under title trust due to the merger of the company
    • Represented a lawsuit for cancellation of donation tax imposition which is unlawful to impose donation tax to shareholders under the enforcement decree of Inheritance and Gift Tax Act when shareholders provide property to a corporation for restructuring or rehabilitation of the company, and have not actually earned a profit
    • Represented the CEO of a company in an administrative appeal and in a nullification action for corporate taxes levied for prepayments and real estate that are irrelevant to business
    • Performed in an action to nullify corporate income taxes levied for alleged unfair calculation
    • Represented in an administrative appeal and in a nullification action for corporate taxes levied related to exemption system for local transfer
    • Advised on obtaining corporate tax review regarding the imputed period for recognizing loss from discontinued business
    • Represented a client in an administrative appeal regarding corporate taxes levied for unissued operating lease invoice
    • Advised on the tax aspects of derivatives, such as Japanese Yen-SWAP time deposits
    • Represented in a nullification action for cancellation of composite income tax imposed on the CEO of a company for alleged unfair calculation
    • Performed in a case to nullify composite income tax levied in the course of transferring the business
    • Performed in an action to cancel levied VAT
    • Performed a case to nullify acquisition tax which is imposed by regarding as oligopoly shareholder under the Local Tax Law in the case of debt-for-equity swap of loans provided by financial institutions in the course of corporate restructuring. Jipyong asserted that the Restriction of Special Taxation Act provides exception for an oligopolistic shareholder
    • Represented a housing association in an action to nullify acquisition and registration taxes levied in relation to acquisition of land and trust registration