SEOUL, May 20 (AJP) -The world of international taxation has never been simple. But in the age of artificial intelligence and digital commerce, it has become extraordinarily complex.
As multinational corporations move capital, data, and services across borders at unprecedented speed, governments around the world are entering an increasingly sophisticated struggle to defend their tax sovereignty. International cooperation aimed at preventing tax avoidance has tightened dramatically, while businesses face mounting pressure to navigate the narrow space between legitimate tax planning and aggressive regulatory scrutiny.
Into this rapidly shifting landscape comes a book that seeks to map the entire terrain.
Kim Myung-jun, the former Commissioner of the Seoul Regional Tax Office, has published a fully revised edition of International Taxation, a comprehensive work widely regarded as one of Korea’s leading practical guides to the field.
The new edition arrives roughly five years after the first publication in 2021 and reflects the profound transformation now reshaping the global tax order.
The author is not merely an academic theorist. He is a career tax official who spent decades at the center of Korea’s international tax administration system. After entering public service through Korea’s highly competitive civil service examination, he served in a series of influential positions, including Tax Attaché to Korea’s Mission to the OECD, Director of the International Tax Investigation Bureau at the Seoul Regional Tax Office, Director of the National Tax Service Investigation Bureau, and ultimately Commissioner of the Seoul Regional Tax Office.
Coming from someone with deep hands in tax investigations, the book offers a deep insight to tax system.
Since retiring from public office, Kim has continued his scholarly and professional work in the field of international taxation. He earned a doctorate from University of Seoul Graduate School of Taxation with research focused on the interpretation and application of the Principal Purpose Test (PPT) and the substance-over-form doctrine under the OECD’s Multilateral Instrument framework designed to prevent Base Erosion and Profit Shifting (BEPS).
He has published numerous academic papers through the Korea International Fiscal Association and was awarded the association’s 2025 International Tax Academic Prize for his study on value-added tax obligations in international B2B service transactions.
Today, he serves as Senior Adviser and Director of the International Tax and Investment Center at Bae, Kim & Lee LLC, one of Korea’s leading law firms.
Yet the significance of International Taxation lies not simply in the résumé of its author, but in the breadth of its intellectual ambition. This revised edition moves well beyond a conventional explanation of tax statutes. It addresses the sweeping transformation of the global tax system in the era of AI and digital commerce, including BEPS 2.0 reforms, the Global Minimum Tax regime, cross-border tax avoidance, and the increasingly contentious struggle over taxation rights in the digital economy.
Particularly notable is the book’s treatment of some of the most difficult and controversial concepts in international tax law, including treaty shopping, beneficial ownership, and the Principal Purpose Test.
Drawing extensively on OECD standards, international case law, and practical enforcement experience, Kim explains these subjects with unusual clarity and precision.
For practitioners, the book functions not merely as a reference volume, but as something closer to a strategic field manual.
International taxation has long been regarded as one of the most difficult disciplines in modern law and finance. Kim attempts to reduce that complexity through an unusually reader-friendly structure that includes approximately 190 transaction flow charts, practical case studies, and carefully sourced references to OECD and United Nations Model Tax Convention commentaries.
The result is a work that enables readers not only to understand abstract legal doctrines, but also to follow the underlying logic of cross-border transactions and international tax disputes.
More importantly, the book approaches taxation not as an isolated legal problem, but as a central component of the emerging global economic order.
The rise of AI-driven platforms and digital services has effectively blurred the traditional meaning of national borders. A multinational company may maintain servers in one country, manage data in another, and generate consumer revenue in dozens more simultaneously. Tax systems designed for the industrial age struggle to adapt to such realities.
As a consequence, governments are racing to construct new taxation frameworks. The OECD-led Global Minimum Tax initiative represents one of the most ambitious attempts in modern history to coordinate international tax policy and limit aggressive tax avoidance by multinational corporations.
For businesses, however, the environment has become increasingly difficult. Regulatory systems overlap, legal interpretations diverge, and compliance risks continue to grow. This is precisely where Kim’s book finds its importance.
Because the author understands both the perspective of the taxpayer and the logic of the tax authority, the book maintains a rare balance between enforcement and compliance, between public interest and private strategy.
The revised edition also separates transfer pricing taxation into an independent future volume. Kim has indicated that a more advanced and specialized work on transfer pricing will be published separately, a development already attracting considerable interest among tax professionals.
The structure of the book reflects the broad scope of modern international taxation.
Part One, “General Theory of International Taxation,” examines the foundations of international tax systems, global tax avoidance, tax administration, international tax audits, and the allocation of taxation rights between states.
Part Two, “Tax Treaty Theory,” addresses treaty interpretation, residency determination, treaty abuse, beneficial ownership, permanent establishments, double taxation relief, mutual agreement procedures, and tax information exchange.
Part Three, “Domestic Source Income Theory,” analyzes taxation issues involving non-residents and foreign corporations, including business income, dividends, royalties, interest income, and personal service income.
Part Four, “Prevention of International Tax Avoidance,” explores anti-avoidance frameworks such as GAAR, SAARs, thin capitalization rules, Controlled Foreign Corporation regulations, hybrid mismatch arrangements, BEPS 2.0 reforms, global minimum taxation, offshore tax evasion, and the emerging challenges posed by AI-era commerce.
Ultimately, International Taxation is far more than a technical handbook for accountants and tax attorneys.
It is, in many respects, a guide to understanding how power, capital, sovereignty, and technology intersect in the twenty-first century.
Today, capital flows across borders instantly. Data moves globally. AI systems operate beyond traditional jurisdictional boundaries. Yet taxation authority remains fundamentally national. The tension between those realities is becoming one of the defining economic and political struggles of our age.
In that sense, this book speaks not only to tax professionals, government investigators, lawyers, and policymakers, but to anyone seeking to understand the deeper architecture of the emerging global economy.
Its greatest strength may lie in the fact that it never reduces taxation to mere technical maneuvering. International taxation is ultimately about fairness, sovereignty, economic strategy, and the moral structure of global capitalism itself.
As artificial intelligence reshapes commerce and human life alike, international taxation can no longer remain a niche concern reserved for specialists alone.
In an era of increasingly fierce global tax competition, International Taxation stands out as a sophisticated compass — a work capable of helping readers navigate one of the most complicated frontiers of modern economic life.
■ About the author: Kim Myung-jun is widely regarded as one of South Korea’s leading experts in international taxation and cross-border tax investigations. After entering public service through Korea’s national civil service examination system, he spent more than three decades within the National Tax Service, building a career at the highest levels of tax administration and international fiscal policy.
Over the course of his career, Kim held several key positions, including Tax Attaché to Korea’s delegation at the OECD, Director of the International Tax Investigation Bureau at the Seoul Regional Tax Office, Director of the National Tax Service Investigation Bureau, and ultimately Commissioner of the Seoul Regional Tax Office.
He became particularly well known for his expertise in multinational corporate taxation, international tax enforcement, and cross-border transaction investigations. Few officials in Korea have possessed such extensive firsthand experience in both the design and execution of international tax investigations.
Following his retirement from government service, Kim transitioned into academic research and professional advisory work.
At University of Seoul Graduate School of Taxation, he completed doctoral research focused on BEPS-related international tax reforms, treaty interpretation, and substance-over-form principles in international tax law.
He has since published numerous scholarly articles addressing BEPS, tax treaty interpretation, value-added taxation in international digital commerce, and anti-avoidance frameworks.
His recent study on VAT obligations in international B2B service transactions earned him the 2025 International Tax Academic Prize awarded by the Korea International Fiscal Association.
Today, Kim serves as Senior Adviser and Director of the International Tax and Investment Center at Bae, Kim & Lee LLC, where he continues to advise corporations, investors, and institutions on international tax strategy and global regulatory developments.
More than anything else, Kim belongs to a rare generation of officials who experienced firsthand the transformation of taxation from a largely domestic administrative function into one of the defining geopolitical and economic battlegrounds of the modern world.
For that reason, International Taxation reads not merely as a professional textbook, but as the intellectual culmination of a lifetime spent at the front lines of global tax policy and enforcement.
Copyright ⓒ Aju Press All rights reserved.