Woowa Brothers, operator of South Korea's top delivery app Baedal Minjok, is under a National Tax Service investigation over suspected offshore tax evasion involving roughly 1 trillion won ($731.5 million) transferred through overseas holding structures between 2024 and 2025. Germany's Delivery Hero is the ultimate parent, while Singapore-based Woowa DH Asia is the intermediate holding company. The NTS treats the transfers as dividends requiring withholding tax of 5% under the Germany treaty or 10% under the Singapore treaty when shareholders hold at least 25%. Woowa Brothers could argue that the transactions were legitimate capital movements and returns of previously invested capital rather than dividend income. The dispute centers on whether the substance-over-form principle permits the NTS to reclassify share buybacks and cancellations as dividends. If the tax authority issues further measures and the company appeals, the case could produce South Korea's first judicial ruling on taxing capital-transaction cash transfers as dividends. Woowa Brothers has not issued an official statement, while the NTS has declined to confirm details of individual audits.