简介
Tae Hyoung Kim is an US Certified Public Accountant (Maine) and Foreign Attorney (D.C.) in the Tax Group at Yulchon LLC. His practice areas focus on transfer pricing and international tax matters for domestic and foreign multinational enterprises. Prior to joining Yulchon, Mr. Kim worked as a CPA in the Global Transfer Pricing Services Team at KPMG Samjong’s Tax Division and in the Tax Group at Yoon & Yang LLC, dealing with various transfer pricing and international tax cases including establishment of global transfer pricing policies, support for mutual agreement procedures (MAP) and advance pricing arrangements (APA), tax due diligence and tax risk assessments, and support for tax audits and tax appeals.
- 2024 University of Connecticut, School of Law，U.S. Law，Executive LL.M.
- 2023 Hallym University of Graduate Studies, Department of American Law，U.S. Law，LL.M.
- 2019 Korea University, Graduate School of Law，Taxation Law，LL.M.
- 2010 University of Illinois at Urbana-Champaign, College of Business，Finance，B.S.
- 2022-present Yulchon LLC
- 2024-present International Cooperation Director，International Fiscal Association Korea
- 2024-present Member，Customs Valuation Committee of Customs Valuation & Classification Institute
- 2019-present Director，Young International Fiscal Association Network (YIN) Korea
- 2015-2022 Yoon & Yang LLC
- 2010-2015 KPMG Samjong Accounting Corp.
- 2025 Admitted to Bar ， District of Columbia (D.C.)
- 2020 US CMA (Certified Management Accountant) ， IMA
- 2016 EA (Enrolled Agent) ， IRS
- 2014 Certified Public Accountant ， Maine
主要业绩
- 2010-present Advised domestic and foreign multinational enterprises in relation to transfer pricing matters, including establishment of global transfer pricing policies, support for tax audits and tax due diligence, support for mutual agreement procedures (MAP) and advance pricing arrangements (APA), and preparation of reports, etc.
- 2015-present Advised domestic and foreign multinational enterprises in relation to international tax matters, such as the application of the denial of unfair transactions rule under the Corporate Income Tax Act (market price analysis for domestic related party transactions), support for tax return amendments (tax refund applications), review of permanent establishment risks and foreign bank account reporting (FBAR) compliance, etc.
- 2015-present Advised domestic and foreign multinational enterprises in relation to corporate customs audits, foreign exchange transaction investigations, and investigations on the FTA country of origin, and review of unfair support transactions under the Monopoly Regulation and Fair Trade Act, etc.
荣誉/获评
- 2023-2026 Next Generation Partner, Tax，Legal 500
- 2022 Best Excellence Award, 5th Juridical Precedent Interpretation Competition，Commissioner of the Korea Customs Service
- 2021 Grand Award, 7th Customs Valuation Research Competition，Commissioner of the Korea Customs Service
- 2021 Best Excellence Award, 4th Juridical Precedent Interpretation Competition，Commissioner of the Korea Customs Service
- 2020 Excellence Award, 6th Customs Valuation Research Competition，Commissioner of the Korea Customs Service
消息/资料
Developments and Legislative Changes for Korean Transfer Pricing Refund Claims, Tax Notes International Vol. 121 No. 1(2026)
Managing MNE subsidiaries during tariff shocks, Journal of Accountancy (co-authored)(2025)
The DEMPE Concept and Its Role in Domestic Transfer Pricing Practice - Report on Korea, IBFD International Transfer Pricing Journal Vol. 32 No. 5a (co-authored)(2025)
Navigating the Gaps Between OECD And Korean Transfer Pricing Rules, Tax Notes International Vol. 119 No. 13(2025)
Korean Transfer Pricing Regulations and Establishing Special Relationship Transactions, Tax Notes International Vol. 119 No. 6(2025)
Recent Korean TP precedents: practical implications for policy and compliance, International Tax Review(2025)
Study on Considerations for Transfer Pricing Analysis based on IFRS 18 -Focusing on the Impact of Changes in Operating Profit from ‘Presentation and Disclosure in Financial Statements’, Tax Journal Vol. 41-1(2025)
South Korea: An Introduction to Tax: Consultants (Key Trends in Tax Audits and Strategic Ways for MNEs to Navigate the Challenges), Chambers and Partners(2024)
Transfer Pricing End-of-Year Adjustments in Korea, IBFD International Transfer Pricing Journal Vol. 31 No. 7(2024)
Study on the Effects and Implications of Customs Valuation by Pillar One Amount B, Tax Journal Vol. 40-2 (Co-Author)(2024)
Recent Korean TP precedents: insights into strategic tax audits and appeal preparation, International Tax Review(2024)
Case Studies in International Tax Law, IFA Korea YIN, Parkyoungsa (Co-Author)(2024)
Study on the Improvements of the Korean Advance Pricing Arrangement Program, Tax Journal Vol. 39-3(2023)
Study on the Improvements of the Korean Advance Pricing Arrangement Program, Tax Journal Vol. 39-3 (Co-Author)(2023)
Study on the Recent Development of the Internal Tax System Based on the BEPS Project and Its Implications on the Customs Valuation -Focusing on the Customs Valuation Implications of the OECD’s “Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic” and Its Customs Valuation Implications, Weekly Customs and Trade Vol. 2017 ~ Vol. 2018 (Co-Author)(2023)
Study on the Considerations for Revision of the Domestic Transfer Pricing Documentation Related Regulation - Focusing on the Transfer Pricing Report and Statements Related Regulations, Tax Journal Vol. 38-3(2022)
Case Study on the Transaction Value Determination of Software Development Costs Supplied Free of Charge for the Customs Valuation Purpose -Focusing on the European Court of Justice’s Judgement of BMW Bayerische Motorenwerke AG v. Hauptzollamt München C-509/19 on 2020. 9. 10., 5th Customs Valuation & Classification Institute’s Juridical Precedent Interpretation Competition (Co-Author)(2022)
Study on the Considerations for Revision of the Domestic Transfer Pricing Documentation Related Regulation - Focusing on the Transfer Pricing Report and Statements Related Regulations, Tax Journal Vol. 38-3 (Co-Author)(2022)
Transfer Pricing Strategies for the New Normal, Strategic Finance September 2022 (Co-Author)(2022)
Proactive Application of COVID-19 Transfer Pricing Rules in Korea, Tax Notes International Vol. 106 No. 8(2022)
Study on the Reasonable Customs Valuation Method from the Effects of the OECD’s Digital Tax, Weekly Customs and Trade Vol. 1970 (Co-Author)(2022)
Study of the Audit on the Customs Valuation Standards Applied to the Multinational Enterprises’ Post-Compensating Adjustments, Journal of Public Audit and Inspection Review Vol. 37 (Co-Author)(2021)
Study on the Transaction Value Determination Method Based on the Reasonable Standards -Focusing on the Effects of the OECD’s Digital Tax Proposal for the Customs Valuation, 7th Customs Valuation & Classification Institute’s Customs Valuation Research Competition (Co-Author)(2021)
Case Study on the Transaction Value Determination for Related Party Advertising Fees and Trademark Royalties for Customs Valuation Purposes -Focusing on the United States Court of International Trade’s Judgement of Trimil S.A. v. United States 16-00025 Case (Slip Op. 19-161) on 2019. 12. 17., 4th Customs Valuation & Classification Institute’s Juridical Precedent Interpretation Competition (Co-Author)(2021)
Study of the Considerations for Improvement and Introduction of the Domestic Transfer Pricing Safe Harbor Regulation, Tax Journal Vol. 37-2 (Co-Author)(2021)
Study of the Guidance for Multinational Enterprises on the Transfer Pricing Implications of the COVID-19 Pandemic -Focusing on the OECD Guidance and Introduction to the Domestic Regulations, Tax Journal Vol. 37-1 (Co-Author)(2021)
Study on the Issues and Reasonable Determination Methods for Customs Valuation of Sales Support and Resale Transactions between Related Parties, 6th Customs Valuation & Classification Institute’s Customs Valuation Research Competition (Co-Author)(2020)
Case Study on Determination of the Transaction Value of Research & Development Fees Paid under Cost-Sharing Agreements in Related Party Transactions for Customs Valuation -Focusing on 2015 FCA 58 Case by the Federal Court of Appeal in Canada, 3rd Customs Valuation & Classification Institute’s Juridical Precedent Interpretation Competition (Co-Author)(2020)
Study on the Board of Audit and Inspection’s Audit on the ‘Implementation of the Arm’s Length Price Calculation Standards’, Journal of Public Audit and Inspection Review Vol. 35(2020)
Study on the Methods and Benefits of Transfer Pricing Documentation Preparation for the Assessment of Imported Goods’ Customs Value, 5th Customs Valuation & Classification Institute’s Customs Valuation Research Competition (Co-Author)(2019)
Case Study on Determination of the Transaction Value for Retroactive Adjustments in Related Party Transfer Pricing Transactions for Customs Valuation -Focusing on the Court of Justice of the EU Case C529/16, 2nd Customs Valuation & Classification Institute’s Juridical Precedent Interpretation Competition (Co-Author)(2019)
Study on the Transfer Pricing Taxation of Multinational Enterprises’ Intra-Group Services -Focusing on the Low Value-Adding Services, Tax Journal Vol. 35-4(2019)
Study on the Transfer Pricing Taxation of Multinational Enterprises’ International Intra-Group Services, Korea University Thesis for the Master’s Degree in Taxation Law(2019)
Study on Recent Global Development of Countermeasures for Harmful Tax Practices -Focusing on the BEPS Project Recommendations and European Commission’s State Aid Investigation, Tax Journal Vol. 34-3(2018)
