YOON&YANG

In November, 2017, Hyundai Engineering sold its shares in CKID Co., Ltd. (a company established in Cambodia, hereinafter “CKID”), in order to sell Phnom Penh Tower, a 22-floor landmark office tower in Phnom Penh, the capital of Cambodia, to Prince Real Estate (Cambodia) Group Co., Ltd., a company in Cambodia which is owned by Chinese shareholders. Hyundai Engineering had de facto ownership over the Phnom Penh Tower through its control over CKID.
 
The significance of this case arises from the fact that Yoon & Yang was able to persuade the purchaser of the viability of a new type of transaction structure in the execution of this sale. Rather than adopting a transaction structure centering around the sale of the building itself, which would lead to the imposition of tax that is equivalent to 4% of value of the building, Yoon & Yang devised the structure around the sale of shares.  This enabled to reduce the tax burden, the imposition of tax (equivalent to 0.1% of value of the shares), and the subject of transfer for Hyundai Engineering.  Yoon & Yang contributed significantly to the successful closing of this deal by providing comprehensive legal advice in terms of deal structuring, drafting of the sales agreements, actively negotiating the sale with the purchaser and more.