The revenue derived from technology transfers pursuant to the Law on Technology Transfers, and IP transfers pursuant to the Law on Intellectual Property, would not be subject to value-added tax (VAT). In the case of contracts for technology transfer or IP transfer accompanied by a transfer of machinery and equipment, only the value of the transferred technology or IP shall not be subject to VAT: where such value cannot be separated, the value of technology or IP transferred with machinery and equipment shall also be subject to VAT.
Source: bloombergtax.com