This report was made for the purpose of discussion with the Korean tax authority during the tax audit period against a foreign subsidiary company doing business in Korea. This kind of tax audit defense approach was a new one at that time. This report was inserted in the book "the International Tax Bible(국제조세바이블)" which was published in January 2012. When this report was made, there was no specific rules concerning the "management service fee (intra-group service fee)" in the Korean Corporate Tax Law and thus there often took place the conflict between taxpayers and tax authorities with regard to the appropriateness of this fee. In order to clarify this controversial matter, the Korean tax authority introduced the new rule concerning management service fee in August, 2006.