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Tax Appeal Service

The highest success rate in the industry — from pre-assessment review to litigation, CENTRIC delivers consistent services.

Service Overview

CENTRIC provides a one-stop service in partnership with DooHyun Law Firm, combining top experts in taxation and law. Recognized for the highest success rate and quality in the industry, our team includes former Tax Tribunal officials, ex-National Tax Service professionals, CPAs, and experienced tax attorneys. Together, we resolve the most complex disputes with accumulated expertise and know-how.

Our mission is to build the strongest legal and tax arguments—ensuring that taxpayers are not unfairly burdened and that tax authorities impose accurate and fair assessments.

With a proven track record, CENTRIC has successfully managed tax appeals for Korea’s top 10 conglomerates, as well as large-scale cases exceeding KRW 100 billion.

Depending on the nature of the case, we carefully select the most effective appeal procedure. Even if the matter escalates to litigation, we provide seamless, consistent services in collaboration with our partner law firm. Since each stage—Pre-assessment Review, Objection, Tax Tribunal Review, and Litigation—is handled by a different authority, our strategies are specifically tailored to each process.

Process of Tax Appeals & Litigation Support
Customized Procedure Selection Establishing Defense Logic Execution of Appeal Procedures
Analyze the nature of the tax assessment
Review past cases and precedents
Assess likelihood of success
Determine tailored procedures and strategies 		Identify and verify facts
Analyze relevant legal relationships
Understand the tax authority’s arguments
Develop counterarguments against tax grounds 		Present logical and persuasive arguments
Prepare written briefs and supporting materials
Ensure thorough preparation for persuasion
Engage in effective communication with authorities
Detailed Services in Tax Appeals & Litigation

Tax appeals allow taxpayers whose rights or interests have been infringed by a tax assessment or disposition to request its cancellation, modification, or other necessary relief.
Remedies include pre-assessment review as a preventive measure, and various post-assessment remedies such as objections, Tax Tribunal appeals, National Tax Service reviews, and administrative litigation.

Pre-assessment Review

A system that allows taxpayers to request a review of a preliminary tax notice issued by the local tax office or, under certain conditions, by the National Tax Service (NTS).
Since this procedure occurs before the final tax notice is issued, it serves as a preventive remedy and provides the advantage of a quick resolution.

Objection

Taxpayers may file an objection with the tax office that issued (or should have issued) the assessment.
Even after filing an objection, taxpayers may still pursue a Tax Tribunal appeal or an NTS review.
However, since the objection is reviewed by the same tax authority that issued the disposition, additional procedures may still be required before proceeding to administrative litigation.

Tax Tribunal Appeal

A procedure to challenge the illegality or unfairness of a tax disposition before the Tax Tribunal, an independent body under the Office of the Prime Minister.
The Tax Tribunal ensures independence and neutrality, and with a large body of precedents, it is widely utilized in diverse cases.

NTS or Board of Audit and Inspection Review

Taxpayers may request a review by the National Tax Service (NTS) or the Board of Audit and Inspection.
Since the NTS review is conducted by the same authority that handles pre-assessment reviews, it is generally not recommended if a pre-assessment review has already been pursued.
Reviews by the Board of Audit and Inspection provide independence and neutrality but differ significantly in procedure compared to Tax Tribunal appeals.

Major Achievements

CENTRIC has achieved outstanding success across all areas of taxation—including corporate tax, VAT, income tax, gift tax, and local taxes—delivering industry-leading results.

  • CENTRIC has achieved outstanding success across all areas of taxation—including corporate tax, VAT, income tax, gift tax, and local taxes—delivering industry-leading results.

  • Timing of overseas sales recognition: Established that recognition occurs when goods arrive at the customer (not shipment date). (KRW 20 billion at issue – canceled)

  • Foundation’s operating income: Proven actual expenditure on public-interest projects. (KRW 9 billion at issue – canceled)

  • Brand royalties: Multiple successful appeals leading to cancellation of unfair assessments regarding royalty payments.

  • Convenience store tax credits: Represented franchisees to redefine investment tax credit scope, leading to cancellation of improper assessments across the industry.

  • Gift tax on stock listing or third-party contributions: Achieved withdrawal of BAI’s imposition.

  • Debt assumption: Secured cancellation of corporate tax of approx. KRW 2.5 billion.

  • Stamp tax omission: Obtained Factual Determination Committee ruling that omission was not fraudulent, canceling local tax of approx. KRW 2.5 billion.

  • Retroactive contract cancellation: Established that it does not constitute deemed donation. (KRW 5.3 billion gift tax – canceled)

  • Public corporation – input VAT: Canceled KRW 9.9 billion VAT assessment through objection procedure.

  • Trust contract timing: Canceled KRW 11.6 billion VAT assessment, confirming supply timing.

  • Gift tax from share value increase: Canceled KRW 12.1 billion assessment.

  • Gift tax on shareholders: Argued successfully that corporate taxation excludes shareholder gift tax. (KRW 13 billion – canceled)

  • Share transfer – unfair calculation: Canceled corporate tax of approx. KRW 18.1 billion.

  • Publishing contract income: Prevented KRW 23.5 billion assessment by proving future expected profits cannot be taxed immediately.

  • Expired gift tax inclusion: Prevented KRW 24.3 billion inheritance tax assessment.

  • Deemed acquisition tax: Canceled KRW 30 billion assessment by proving stock acquisition from qualified split is excluded.

  • Unlisted stock acquisition: Prevented KRW 33.1 billion corporate tax through Pre-assessment Review.

  • Multinational bank VAT: Represented NTS in KRW 33.7 billion case, establishing standards for taxation of electronic service transactions.

  • Foreign stock acquisition: Canceled KRW 40 billion gift tax by proving genuine acquisition, not nominee arrangement.

  • In-kind capital contribution: First-ever ruling canceling KRW 50 billion gift tax on repeat nominee arrangements.

  • Home shopping company VAT: Prevented KRW 57.3 billion assessment via Pre-assessment Review, setting a precedent for industry-wide audit standards.

  • Holding company royalties: Canceled KRW 130 billion corporate tax by proving appropriateness of brand royalty payments.

  • Gift tax on shareholders (KRW 130 billion): Tribunal ruled no nominee gift taxation applies if shareholder register transfer is not duly completed under corporate law.

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