Tax Opinion Letters
We prepare expert tax opinion letters on specific tax issues, suitable for board reporting, tax audit responses, and internal approval documentation.
Coverage Areas (Examples)
Tax opinion letters are effective in a wide range of situations. Below are the main subject areas we cover.
Corporate & Income Tax
We provide written analysis of key corporate and income tax questions — deductibility, reorganization taxation — that also serves as support in a tax audit.
Examples： Transaction tax classification / Corporate reorganization tax (qualified/non-qualified) / Officer compensation tax treatment / Group taxation regime
Consumption & Indirect Tax
We document consumption-tax positions — taxability classification, invoicing, cross-border digital services — where early clarity prevents compounding errors.
Examples： Taxable / exempt / zero-rated classification / Invoice system compliance / Cross-border digital service taxation / Real estate and consumption tax
M&A & Restructuring
We deliver written tax analysis for M&A — share vs. asset deal comparison, qualification requirements — with calculations and reasoning timed for the decision.
Examples： Share vs asset deal tax comparison / Merger/split qualification requirements / Goodwill & business rights tax treatment / Favorable issuance / deemed dividend
Digital & Emerging
We opine on tax questions with little precedent — crypto assets, NFTs, stock options — laying out the available options and their risks against current law and rulings.
Examples： Crypto asset / NFT tax treatment / Stock option tax rules (qualified/non-qualified) / SaaS / subscription invoice compliance / Generative AI service tax issues
Our Strengths
Evidence-Based, Practical Opinions
Our tax accountants and CPAs draft each opinion with precise citations of statutes, rulings, and precedents — structured to be used directly in tax audits or board presentations.
Combined Legal & Tax Opinions
In M&A and restructuring, tax and legal issues are inseparable. With legal work handled within the firm alongside tax, we examine the legality of a scheme and its tax consequences at the same time — and can issue legal and tax opinions as a set.
Up-to-Date on Tax Authority Trends
Credible tax opinions depend on current knowledge of rulings and enforcement trends. We continuously monitor tax authority developments to ensure our opinions are up to date.
FAQ
Q. How does a tax opinion letter relate to a tax audit?
A tax opinion letter creates a formal contemporaneous record of the rationale behind a transaction or tax treatment choice. It serves as supporting documentation in a tax audit when explaining why a particular treatment was adopted. That said, the opinion does not bind the tax authority — the final determination rests with the authority or the courts.
Q. When should we obtain a tax opinion during M&A scheme analysis?
Most clients obtain a tax opinion during due diligence around the LOI stage, or during final condition-setting before the definitive agreement. Confirming tax risks before the scheme is finalized reduces the risk of unexpected tax burdens emerging later. A tax opinion is also useful at the stage of choosing between a share deal and an asset deal.
Q. How long does it take to prepare a tax opinion letter?
For a standard matter, approximately three to four weeks, depending on complexity and scope of research. We can also accommodate tight M&A schedules on a priority basis — please contact us to discuss.
Q. Can we obtain a legal opinion and a tax opinion at the same time?
Yes — with legal and tax work both handled within the firm, we prepare legal and tax opinion letters concurrently. Being able to confirm both the legal validity and tax treatment of a transaction in one integrated process is particularly valuable in M&A and new scheme implementations.
Q. How is a tax opinion letter different from a pre-filing ruling request to the tax authority?
A ruling request to the National Tax Agency provides an official government position, but carries disclosure risks, takes months to receive, and is limited in the scope of issues it can address. A tax opinion letter is private, obtained quickly, and well-suited for internal deliberation and decision-making. Both approaches can also be used in combination.
Q. Do you also handle personal tax issues such as inheritance or real estate?
Yes — beyond corporate tax, we address personal tax issues including inheritance tax, gift tax, taxation of real estate disposals, and valuation of unlisted shares for inheritance tax purposes. We also prepare tax opinion letters relating to owner-manager succession and asset reorganization.
Get in Touch
We will listen to your concerns and propose the most suitable service. Initial contact creates no contractual obligation.
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