Reporting requirements of Base Erosion and Profit Shifting (“BEPS”)

CRIT

Local file and Master file

CbC report

Conditions

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. Annual overseas specially related party transaction exceeds KRW 50 billion.

Ÿ In the case where the ultimate parent company is a domestic company or a resident of Korea, the CbC reporting obligator is the domestic parent company preparing the consolidated financial statements of a multinational group whose consolidated revenue exceeds KRW1 trillion during the preceding fiscal year.

Ÿ In the case where the ultimate parent company is a foreign company or a non-resident of Korea, the CbC reporting obligator is a Korean affiliated company of a multinational group whose consolidated revenue exceeds 750 million Euros (or equivalent) in the preceding fiscal year if any of the following conditions are met:

a. There is no obligation to submit a CbC report under the laws and regulations of the country where the ultimate parent company is located; OR

b. There is no arrangement for the exchange of CbC report information between South Korea and the country where the ultimate parent company is located; OR

c. The Korean affiliated company did not submit CbC Reporting Notification within 6 months from the end of each fiscal year (e.g. by June 30, 2020 for the Korean company having the fiscal year ended December 31, 2019).

Due date

Within 12 months from the end of each fiscal year (e.g. by December 31, 2020 for the MNE having the fiscal year ended December 31, 2019).