Korean Tax Newsletters
Introduction of Horwath Choongjung TP Team
1. Introduction of Horwath Choongjung TP Team
Horwath Choongjung LLC, a member of Crowe Horwath International, is excited to announce renovation of Korea Transfer Pricing Services in response to increasing demand for specialized transfer pricing related services.
We recently recruited a transfer pricing specialist, Jae K. Lim, who has extensive experiences in transfer pricing issues for more than 10 years of practices in PwC and E&Y. He will lead the transfer pricing dedicated team which is composed of expert CPAs.
The transfer pricing team is dedicated to quality transfer pricing services specially designed for each company’s specific needs and practical solutions.
The Transfer Pricing Team provides;
■ Transfer Pricing Documentation and Transfer Pricing Update Study Service;
■ Assistance Service for Transfer Pricing Tax Audit and Tax Appeal;
■ Assistance Service for Advance Pricing Agreement and Mutual Agreement
■ Customs Valuation Service related to Transfer Pricing Issues;
■ Global Transfer Pricing Documentation and Establishment of Global Transfer
Pricing Policy Service; and
■ Other Services related to Intra-group Service Fees, Royalty, Interests,
Permanent Establishment, Cost Sharing, Tax Havens, Thin Capitalization,
and international taxes.
In addition to above standardized transfer pricing service, we particularly plan to provide transfer pricing services specialized for small and medium-sized companies since we well acknowledge growing needs for transfer pricing services independently tailored for each company’s specific business environment and requirements.
Examples of service programs specialized for small and medium-sized companies are as follows:
■ Outbound Transfer Pricing Services
Due to the globalization, there are a number of small and medium-sized companies who have significant amount of trade with its overseas related parties. In addition, many foreign tax authorities (e.g., US, Chinese, and European) are continuing or starting to pay close attention to transfer pricing issues related to Korean subsidiaries and branches. In contrast to the current changes in the worldwide taxation environment, many small and medium-sized companies are not prepared against potential transfer pricing challenges from foreign and Korean tax authorities.
Thus, we offer Outbound Transfer Pricing Service for small and medium-sized companies which is highly customized for company-wise specific needs and solutions. The service includes 1) setting global transfer pricing policy, 2) country specific documentation, 3) comparable search for foreign market, 4) global transfer pricing planning and documentation, 5) cost management for transfer pricing purpose, and 6) consultation on customs, foreign exchange regulations and other related international tax issues.
■ Transfer Pricing Service specialized for Tax Filing Purpose
In order to claim underreporting penalty waiver, the law specifies that companies should possess supporting documents including transfer pricing report by the time of filing tax return. However, a number of small and medium-sized companies do not have related documents simply because they do not know what to do with their overseas intercompany transactions, or they are not satisfied with service fees. Thus, we offer a Transfer Pricing Service specialized for small and medium-sized companies and strengthened with more efficient service skills and more affordable service fees.
■ Transfer Pricing & Customs Valuation Service
It often becomes a big issue for many companies, having intercompany transactions with overseas related parties, when basis of determining import price should meet two different standards required under Korean customs regulations and transfer pricing regulations. In particular, companies are subject to two different audits conducted by customs office and tax office on the matters of import prices. Thus, we can offer a Transfer Pricing Services which will satisfy the needs for both customs valuation and transfer pricing issues.
■ Establishing Cost Management Manual Service for Transfer Price and Customs Valuation Purpose
When establishing transfer price or implementing new transfer pricing policy, companies often face with the questions how to manage inventory costs in line with related regulations. Thus, we offer the Cost Management Manual Service which will help companies to manage inventory in accordance with transfer pricing and customs valuation regulations.
■ Comprehensive Transfer Pricing Service
Based on our strong background on various international tax issues, we offer Comprehensive Transfer Pricing Service which covers not only transfer pricing issue but also international and domestic tax issues.
Crowe Horwath International has a number of transfer pricing specialists in more than 140 independent accounting and advisory services firms with 590 offices and 28,000 professionals and staff in more than 107 countries around the world which we believe will ever more strengthen us in providing quality services.
■ Contact Information
Jea Dong Seo, Tax Partner
Jae K. Lim, Transfer Pricing Director***
***Jae K. Lim is in-charge Director of Transfer Pricing Team. He holds more than 10 years of professional experiences in transfer pricing field from PwC and E&Y. He holds US CPA license. His professional experience includes service for Advance Pricing Agreement (APA) and Mutual Agreement Procedure (MAP), audit defense service, global outbound TP planning service, transfer pricing service for financial companies, customs valuation service, transfer pricing documentation service, cost sharing service and other issues such as royalty, loan transaction, permanent establishment, stock transfer, management service fee, etc.***