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Foreign businesses sometimes complain of the NTS’s inconsistent execution of tax audit practices in some cases, especially in the field of transfer pricing probes.
We are confident in our ability to help our clients come to the best solution in any circumstances in the dynamic Korean market.
Here is a brief overview of our transfer pricing work procedure.
- 1. Analyze intercompany transactions, including pricing, functions, terms of contract, economic environment, accompanying risks and other relevant factors.
- 2. Search for the best method and most suitable comparables, when needed.
- 3. Reconcile differences in compared transactions.
- 4. Determine arm’s-length price or range through economic, statistical and legal methods.
- 5. Document and support the validation of transfer price.
- 6. Represent and support our clients in case of conflicts with tax authorities.
If you have any questions regarding your company’s transfer price policy and other international taxation matters, please do not hesitate to contact us.
Advance price agreement and mutual agreement
Permanent establishment issues including dependent agent and application of tax treaties
Incorporation, management and closing of foreign companies’ Korean branches or subsidiaries