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  • AMCHAM Taxation Committee Meeting
    • DATE & TIME

      Friday, May 22, 2026

      2:00 PM - 3:30 PM

    • VENUE

      Bae, Kim & Lee (BKL) Office | Centropolis Building, Tower B, 25th Floor Seminar Hall (26 Ujeongguk-ro, Jongno-gu, Seoul)

    EVENT DESCRIPTION
    This session will provide an in-depth exploration of the 2026 Manual on Effective Mutual Agreement Procedures (MEMAP), recently released by the OECD. The manual offers comprehensive guidance for both competent tax authorities and taxpayers, covering all key aspects of accessing and operating the mutual agreement procedure (MAP) under tax treaties. It also sets out a wide range of practical best practices aimed at improving the efficiency and effectiveness of MAP processes.

    Participants will gain valuable insights into the implications of the manual for both taxpayers and tax administrations, as well as its broader impact on the evolving tax controversy landscape and the overall functioning of dispute resolution mechanisms.

    The session will conclude with forward-looking perspectives on the OECD’s tax certainty agenda, highlighting emerging trends and what lies ahead for international tax dispute prevention and resolution.

    Detail
    TOPIC 2026 Manual on Effective Mutual Agreement Procedures (MEMAP)
    COST KRW KRW 0 for members
    KRW KRW 0 non-members
    RSVP/PAYMENT BY Noon, Wednesday, May 20, 2026
    About the Speaker

    • Dr. Robert J. Danon, Professor of Law, University of Lausanne
      Robert J. Danon is a tenured Professor of Law ("Professeur ordinaire") at the University of Lausanne (Switzerland), where he heads its Tax Policy Center and leads its research platform dedicated to Tax-Related Disputes and International Arbitration. He has published, edited or co-edited over 150 articles or books in most areas of domestic, international tax law and investment law. He is a co-editor of the two forthcoming volumes: "Tax Matters in International Investment Arbitration" (Danon/Wuschka/Ziegler ed.) and "Tax Treaty Interpretation under the Vienna Convention on the Law of Treaties" (Danon/Maisto/Martin Jiménez ed.)

      With over 25 years of professional experience in domestic and international taxation, Professor Danon is recognized internationally as combining deep academic insight with extensive practical expertise in resolving complex tax controversies and advising on the evolving global tax landscape.

      Professor Danon serves or has served on the board of various leading organizations and associations dealing with taxation matters. From 2017 to 2025 he was the Global Chair of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA) - the world’s foremost tax association, founded in 1938 and present in 116 countries – and was subsequently appointed as Honorary Member.

    • Jeremy Everett, Managing Director, Tax, Alvarez & Marsal Korea, LLC
      Jeremy Everett has 31 years of international tax experience, including 10 years at Big 4 Accounting Firms, 10 years in-house as the global tax head of the Doosan Group and Korean tax head of the GE Group, and 11 years at Korea's top law firms.

      Mr. Everett assists clients with tax and customs audit defense, transfer pricing (including MAP and APA cases), ACVA (the customs equivalent of an APA), tax dispute resolution (including Tax Tribunal and Court appeals), M&A, cross-border tax planning, tax ruling requests, government advocacy, and investment incentives (e.g., cash grant applications). He has broad industry experience, including healthcare/pharma, luxury goods, ICT, energy, real estate & private equity, manufacturing, and distribution.

      Mr. Everett has served as Co-Chair of Amcham Korea's Tax Committee from 2004-2011 and again since 2023. He led AMCHAM's CFO Committee from 2015-2023 and has led the Indian Chamber of Commerce Speaker's Forum since 2016.

    • Kyung Geun Lee, Senior Advisor, Bae, Kim & Lee LLC
      Kyung Geun Lee is a distinguished international tax advisor with over 40 years of experience and is widely recognized as one of Korea’s foremost authorities on cross-border taxation and transfer pricing. His practice focuses on complex international tax issues arising from foreign companies’ entry into Korea, mergers and acquisitions, outbound investments, transfer pricing (including APAs), tax treaty interpretation and mutual agreement procedures, and high-stakes tax litigation.

      Consistently ranked Band 1 in Tax by Chambers Asia-Pacific since 2013, Mr. Lee has advised leading multinational corporations and major Korean conglomerates across a broad range of industries, as well as global financial institutions, on sophisticated tax planning, controversy, and dispute resolution matters. He also successfully led legislative initiatives enabling subsidiaries to deduct stock-based compensation expenses paid to parent companies.

      Prior to private practice, Mr. Lee held senior leadership roles at Korea’s Ministry of Strategy and Finance, where he negotiated amendments to tax treaties with major jurisdictions and drafted the Act on Adjustment of International Taxes in 1995, laying the foundation for Korea’s modern transfer pricing regime. He served at the OECD Secretariat (1999–2003), was Vice Chairman of the UN Committee of Experts on International Cooperation in Tax Matters (2005–2007), later participated as a private expert on its Transfer Pricing Subcommittee, and served as President of the Korea International Fiscal Association (IFA Korea) in 2019.

      He currently serves at Bae, Kim & Lee LLC (2025–Present), following senior roles in private practice, academia, and government, bringing unparalleled policy, academic, and practical insight to complex international tax matters.

    • Steve Minhoo Kim, Senior Foreign Attorney, Lee & Ko
      Steve M. Kim is one of leading international tax partners at Lee & Ko, where he primarily advises foreign-invested companies doing business in Korea, as well as Korean multinational groups on outbound tax matters.

      Throughout his career, Steve has handled a broad range of international tax engagements across diverse industries, including direct and indirect tax-driven restructurings, tax due diligence, transfer pricing planning and policy design, permanent establishment risk assessments, withholding tax matters involving income characterization and beneficial ownership issues, tax audits, and related dispute resolution proceedings, including administrative appeals, tax litigation, and mutual agreement procedures.

      Steve has also handled numerous inbound and outbound advance pricing agreement (APA) matters across a wide range of industries, advising clients on APA strategy, transfer pricing analysis, documentation, negotiations with tax authorities, and implementation of agreed methodologies.

      Steve is admitted to practice law in Washington, D.C. and is also a certified public accountant. He has been recognized by International Tax Review as one of Korea’s Highly Regarded transfer pricing practitioners since 2024 and was named Asia-Pacific Transfer Pricing Practice Leader of the Year by International Tax Review in 2023. He regularly contributes to tax and legal publications on international tax matters. He currently serves as Co-Chair of the Taxation Committee of AMCHAM Korea and is a frequent speaker on international tax and transfer pricing topics at events hosted by the International Fiscal Association and other leading professional organizations.

    • Joon-Kyoo Yang, Managing Director, PwC Korea
      Joon-Kyoo Yang is a Managing Director at  PricewaterhouseCoopers’ Transfer Pricing Practice. With over 30 years of transfer pricing experience, Joon serves clients in a wide breath of industries and geographic regions. His experiences include APAs, dispute resolutions, global planning, and documentation studies. ​
      ​
      Joon is also actively involved with Samil PricewaterhouseCoopers’ customs practice. His customs experiences include risk assessments, multiregional customs planning and implementation, and customs audit defense.​​
      ​
      Joon frequently serves as an instructor at technical training seminars and training events. He also served as a guest speaker at a graduate course at Korea’s Seoul National University and at a national training seminar for China’s tax authorities.  ​​​
      ​
      Prior to joining PricewaterhouseCoopers, Joon was an analyst for a litigation consulting firm providing clients with statistical and economic consulting services.  Joon has a ​B.S. degree in Economics, California State Polytechnic University, Pomona, with emphasis on econometrics, statistics and industrial organization.
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  • American Chamber of Commerce in Korea
    Address
    50Fl., Three IFC, 10, Gukjegeumyung-ro, Yeongdeungpo-gu, Seoul 07326, Korea
    Name of Representative
    James Kim
    Business Registration No
    771-82-00210
    E-Commerce No
    2019-서울영등포-0027
    E-mail
    amchamrsvp@amchamkorea.org / membership@amchamkorea.org
    Monday through Friday, 9:00am to 6:00pm (Closed on Korean Public Holidays.)
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