SCTP: Explore East Asia’s Evolving Tax Disputes Terrain (In-Person. FOC for Members.)


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Recommended: Get the key updates on tax audits, disputes, and litigation in Japan and Korea
Date:
14 August 2025, Thursday

Closing date: 7 August 2025, Thursday or when spaces are filled

Time:
09.30AM - 12.00PM

Registration starts at 9:00am

Venue:
TBC (In-Person)

CPE Hours (Income Tax):

2 hour(s)

CPE Hours (GST):

0 hour(s)

Fees:
(w/GST): FOC (SCTP Member); $129.71 (ISCA/ Association Member); $174.40 (Non-Member)
Contact:
Contact Nabila (+(65) 6360 5969), Anna (+(65) 6360 5979) or enquiry@sctp.org.sg
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Programme Synopsis

Amid global shifts in tax enforcement and governance, East Asia is seeing pivotal developments in its tax disputes landscape. Recent litigation trends, including high-profile tax and transfer pricing (TP) disputes such as the recent Tokyo High Court decisions in the IHI case and the NGK case, as well as challenges to international tax rulings, underscore Japan’s growing focus on enforcement and cross-border compliance.

Over in South Korea, a heightened scrutiny on the newly formed Korean administration has brought on a call for enhanced transparency and fairness in tax administration, with an amplified focus on digital transactions, cross-border income and corporate restructuring, just to name a few. 

As for tax disputes, the recent Supreme Court decision in the Lone Star Funds case regarding which entity (i.e, the taxpayer vs. withholding agent) has the right to claim refund for tax withheld at source is noteworthy for its implications on cross-border taxation and procedural tax rights. The classic dichotomy between royalty and business profit has also been in the spotlight in income classification disputes. 

Come hear directly from Mr Ryutaro Oka, Partner at Baker McKenzie (Gaikokuho Joint Enterprise), Mr Luke Tanner, Partner at Baker McKenzie (Gaikokuho Joint Enterprise), Mr Jangwoon John Kwak, Partner at Baker McKenzie & KL Partners Joint Venture Law Firm and Ms Seonhye Kim, Senior Associate at Baker McKenzie & KL Partners Joint Venture Law Firm as they unpack the latest tax developments and litigation trends in Japan and South Korea.

This not-to-be-missed half-day in-person session is designed for tax professionals, legal advisers, and businesses looking to stay ahead of audit trends, litigation risks, and evolving dispute resolution procedures across the East Asia region.

Programme Outline

  • Stay up to date with recent tax audit trends:
    - Gain a deeper understanding of Japan’s tax authority structure and its recent organisation changes
    - Discover what to expect in tax legislation and policy under South Korea’s new administration
    - Explore the evolving tax audit procedures and recent trends, including focus areas recently highlighted by both authorities
  • Dive deeper into the region’s tax litigation and dispute resolution procedures:
    - Understand the various options for dispute resolution, including domestic mechanisms and treaty-based approaches
    - Examine transfer pricing-related controversies and specialised resolution pathways
    - Navigate the key steps and considerations in the tax litigation process and practical considerations for managing disputes in Japan and South Korea
    - Review landmark court decisions from notable recent court cases and assess their broader implications for future tax risk management, tax policy and compliance matters.

SCTP reserves the right to vary any aspect of the event/ webinar should the situation warrant or due to unforeseen circumstances. This includes but not limited to the following: cancel the programme, change the venue, speakers, programme dates, fees and CPE hours. SCTP will take reasonable effort to notify participants of the changes.

About the Facilitator(s)


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Mr Ryutaro Oka
Partner
Baker McKenzie (Gaikokuho Joint Enterprise)


Ryutaro Oka has significant experience in the finance, trade, energy and manufacturing industries, where he has developed and maintained good client relationships. He regularly advises on complex international tax issues, working extensively with colleagues in the US, UK, Netherlands, China, Singapore and Thailand. Mr. Oka is a frequent speaker on international tax issues, having been invited to speak on international taxation and cross-border private equity investments at events sponsored by the Association of Taxation Analysis, among others. Prior to joining the Firm in 2006, Mr. Oka was a tax director at Deloitte Touche Tohmatsu's Tokyo office, where he advised on international tax issues. Mr. Oka is fluent in English. 

Mr. Oka's main practice focus is cross-border M&A taxation. In this connection, he routinely advises on overseas holding company schemes, including the formulation of worldwide tax-efficient acquisition structures, tax due diligence issues, as well as other international taxation matters. He advises as well on the structure of international PE funds and hedge funds. Mr. Oka also advises large family owned companies, and provides succession planning strategies for the founding owners of those companies. Additionally, Mr. Oka handles general taxation matters, including organizational restructuring, and advises regarding Japan's consolidated taxation system. 

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Mr Luke Tanner
Partner
Baker McKenzie (Gaikokuho Joint Enterprise)


Luke Tanner is a Tax & Transfer Pricing partner. He is based in Tokyo, and is also responsible for Asia Pacific regional transfer pricing.  
  
Luke is an experienced tax lawyer, and has advised clients on international tax matters and cross-border M&A transactions, including reorganisations, due diligence, reviewing financial models and legal agreements, financing and structuring, tax effective profit repatriation and exit strategies.  

Luke also has extensive experience in transfer pricing including over a decade of practicing transfer pricing in a Big 4 accounting firm. His experience includes pricing policies involving profit splits and intellectual property transactions, permanent establishment profit attribution and intra-group financing. He has a particular focus on transfer pricing controversy, including assistance with tax and transfer pricing audits and obtaining bilateral APA and MAP agreements involving many jurisdictions including Singapore and Japan. 
 
Luke has practiced in several Asia Pacific jurisdictions, including Australia and Japan.

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Mr Jangwoon John Kwak
Partner
Baker McKenzie & KL Partners Joint Venture Law Firm


John Kwak is a partner leading the tax practice of Baker McKenzie & KL Partners Joint Venture Law Firm. John's practice focuses on the tax aspects of a wide range of cross-border corporate transactions and investments. 

John is a seasoned lawyer with over 20 years of experience in international taxation and cross-border transactions. He has successfully represented multinational corporations in tax audits, tax litigation, dispute resolution, transfer pricing, M&A tax structuring, and overseas investment strategies. 
 
John is particularly skilled in navigating corporate tax and transfer pricing challenges for foreign companies operating in Korea, while also resolving complex tax and regulatory issues for Korean companies expanding abroad. His expertise has been essential in helping multinational clients manage tax risks and optimize compliance in an increasingly complex global tax landscape. John also provides high-net-worth individuals and their private businesses with tailored cross-border tax and estate planning solutions. 

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Ms Seonhye Kim
Senior Associate
Baker McKenzie & KL Partners Joint Venture Law Firm


Seonhye is a Senior Associate at Tax Practice of Baker McKenzie & KL Partners Joint Venture Law Firm. Her practice focuses on tax dispute resolution, including tax litigations, administrative appeals to tax tribunals, Mutual Agreement Procedures, etc.  

As a qualified Korean attorney, Seonhye has represented numerous domestic and international corporations in tax audits, appeals, and litigation and advised on a wide range of cross-border tax matters. Her expertise in international taxation spans multiple industries, including ICT and digital business, virtual assets, and industrial and consumer goods. 








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