Transfer Pricing(TP) and BEPS Requirements


Under the ITCL, which governs the taxation of international transactions between taxpayers and overseas specially related parties (OSRP), a company is obliged to submit the following documents for the transactions made with its OSRPs during the fiscal year to the relevant tax office together with its annual corporate income tax return:

  • “Schedules of international transactions”
  • “Report on Arm’s Length Price Determination Method”
  • “Summary Profit and Loss Statement of OSRP”


In addition, from FY2016, Multinational Enterprises (MNE) which meet the following conditions are also required to submit the Combined Report of International Transactions (CRIT) which is comprised of three elements (Local file, Master file, and CbC report).




Local file and Master file

CbC report


Domestic corporations and foreign corporations with a domestic place of business that satisfy the following criteria:

a. Annual gross sales of an individual entity exceed KRW100 billion;and

b. International related party transaction exceeds KRW 50 billion per year.

Domestic (Korean) ultimate parent company of multinational enterprises with annual sales revenue exceeding KRW 1 trillion per consolidated financial statements for the preceding year

Due date

within 12 months from the end of each fiscal year (as revised from within 3 months from the fiscal year-end previously)

within 12 months from the end of each fiscal year