The government announced the following change to the Enforcement Regulations of International Tax Coordination Law (ITCL- ER) which came into force from the fiscal year starting on or after January 1, 2015.
Transfer Pricing Rules - Requirements for Submission of Summary Profit and Loss Statement of Overseas Specially Related Parties (Article 6-2 of ITCL - ER)
A company which meets the following conditions may not submit the summary profit and loss statement of overseas specially related parties (OSRP) under the previous regulations:
(1) Goods transactions (both sale and purchase) with each OSRP shall not exceed Won 1 billion per year; AND
(2) Service transactions (both rendered and received) with each OSRP shall not exceed Won 100 million per year.
However, under the revised ITCL- ER, the threshold of condition (2) above was increased to Won 200 million per year.