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Tax
Tax
Overview
Tax issues directly affect transaction structures and corporate value, making advance planning essential.
Tax law is complex and frequently amended, requiring sophisticated interpretation tailored to specific facts and meticulous evidence management.
At the investigation and assessment stage, identifying key issues, constructing legal arguments, and developing document submission strategies determine outcomes.
Cross-border tax risks — including international transactions, double taxation, and transfer pricing — are also expanding.
The LIN Tax Team provides comprehensive advisory covering domestic and international tax issues, tax investigation response, and complex transaction structures.
Key Services
Corporate tax, VAT, withholding tax, and local tax advisory and risk diagnosis
Tax investigation response, pre-assessment adequacy review, objection, examination/adjudication, and appeal procedures
M&A, investment, and governance restructuring tax structuring and tax due diligence
International tax (transfer pricing, withholding tax, PE, tax treaties) advisory and dispute response
Estate, gift, business succession, and asset transfer tax strategy formulation
Key Experience
1. Tax Litigation
Acquisition tax revocation litigation: Related to asset acquisition costs
Resident tax revocation litigation: Related to fulfillment of local tax exemption requirements for business establishments
Securities transaction tax revocation litigation: Related to transfer value of unlisted shares
Gift tax revocation litigation: Related to major shareholder related-party transaction gifting, and secondary tax liability for major shareholder dividend income
Corporate tax revocation litigation: Related to tax special treatment
Inheritance tax revocation litigation: Related to valuation of inherited property
Foreign account under-reporting penalty revocation related