Additional exemption for submission requirements of transfer pricing documents
- Additional exemption for submission requirements of transfer pricing documents
• Under the International Tax Coordination Law of Korea (“ITCL”), taxpayers conducting cross-border transactions with overseas specially related parties (“OSRP”) are required to submit the following information.
- Schedules of international transactions (with OSRP)
- Summary Profit and Loss Statement of OSRP
- Report on the method of the arm's length price determination for the intangible asset, service provision, and other transactions, respectively
• However, the submission requirements will be exempted if the following conditions are met.
- Schedules of international transactions
|
Current |
Addition in the tax reform bill |
|
A Master File and a Local File are submitted |
Or total transaction amount of goods, services, or intangible assets with OSRP does not exceed KRW 500 million, 100 million, or 100 million, respectively. |
- Summary Profit and Loss Statement of OSRP
|
Current |
Addition in the tax reform bill |
|
Transaction amount of goods and services with each OSRP does not exceed KRW 1 billion and 200 million, respectively |
And transaction amount of intangible assets with each OSRP does not exceed KRW 200 million |
- Report on the method of the arm's length price determination
|
Current |
Addition in the tax reform bill |
|
Total transaction amount of goods and services with OSRP does not exceed KRW 5 billion and 1 billion, respectively |
And total transaction amount of intangible assets with OSRP does not exceed KRW 1 billion |
|
Transaction amount of goods and services with each OSRP does not exceed KRW 1 billion and 200 million, respectively |
And transaction amount of intangible assets with an OSRP does not exceed KRW 200 million |