Tax Law Interpretation(Advance Tax Ruling)

We assist clients by obtaining advance tax rulings from the tax authorities and thereby reducing tax uncertainty. The team includes former government officials from the tax authorities, lawyers, certified public accountants, and tax attorneys, working together to minimize taxpayer risk.

Introduction
Professionals

Introduction

Tax implications are not always clear. If a taxpayer undertakes a transaction based on their own assessment but the tax authorities later take a different view, significant tax liabilities, including penalties, may be assessed. Had such risk been identified in advance, the transaction could have been structured differently. Discrepancies between the taxpayer’s assessment and the authorities’ position can lead to disputes (including tax litigation and administrative appeals) with substantial time and cost burdens on the taxpayer. Our team works to prevent such situations by obtaining advance tax rulings from the authorities and thereby reducing tax uncertainty. Applying for an advance tax ruling requires a clear understanding of the contemplated transaction, well-supported reasoning on how the applicable tax law should be interpreted and applied, and active engagement to persuasively present the taxpayer’s position to the authorities. Our team includes former government officials from the National Tax Service and the Ministry of Economy and Finance, along with lawyers specializing in tax, certified public accountants, and tax attorneys. Working as a unified team, we have extensive experience in obtaining favorable advance tax rulings. We are committed to helping taxpayers mitigate tax risk and conduct transactions with greater certainty and confidence.