Under the 2015 Tax Revision Bill, Korea is planning to implement new transfer pricing reporting requirements for multinational enterprises, including a new report on international transactions. The contents of the report are based on the guidelines developed as part of Action 13 of the OECD BEPS Project, and include:
The new requirements are to apply for Korean resident companies and permanent establishments of foreign companies meeting certain transaction thresholds (TBD) for tax years beginning on or after 1 January 2016. The due date for the report will be the same as the annual tax return (generally three months following the year-end, four if filing a consolidated return).
One of the key components of the Action 13 guidelines, the country-by-country (CbC) report, is not included in the current transfer pricing report proposal. The Korean Ministry of Strategy and Finance has reportedly decided to implement the CbC requirement after the Master and Local File requirements in order to alleviate the increased compliance burden multinationals will face.
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