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South Korean Tax Tribunal Holds Interest Deduction Not Denied for Tax Avoidance May Still be Subject to Arm's Length Adjustment

|Approved Changes|South Korea
South Korea

According to recent reports, the South Korean Tax Tribunal has issued a decision regarding a tax authority challenge of a taxpayer's deduction of interest paid to a U.S. related party. The interest arose following a series of transactions that resulted in a U.S. company acquiring all of the equity interests in the taxpayer, a Korea-U.S. joint venture, with the U.S. company also becoming a lender to the taxpayer. When the taxpayer sought to deduct interest paid to the U.S. company, the Korean …

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