Transfer Pricing

"They always provide accurate and timely feedback in layman's terms. We appreciate the team's ability to easily understand and analyse complex matters."

- Chambers & Partners Asia-Pacific

Overview

For multinational corporations increasingly engaging in cross-border transactions, having appropriate transfer pricing policies in place is becoming more critical than ever.

Transfer pricing is a controversial issue among tax authorities and requires a coordinated response beyond the borders of one tax jurisdiction. However, insufficient understanding of tax trends and practices, and transfer pricing requirements of the target country of investment has exposed more and more corporations to excessively high tax risks in carrying on their business activities. Moreover, these tax risks are becoming more challenging as tax jurisdictions become more proactive in regulating tax havens and actively exchanging tax information.

BKL understands the importance of effectively managing cross-border transactions and transfer pricing arrangements, and our Tax Group consists of a dedicated team of professionals to provide comprehensive solutions to address transfer pricing issues, consisting of attorneys and certified public accountants with in-depth experience in international tax matters and certified tax accountants having hands-on experience at the National Tax Service on transfer pricing audits.

In particular, our Tax Group has the expertise to assist in preparing transfer pricing policies, drafting transfer pricing reports, assisting with advance pricing agreements (APA), representation in mutual agreement procedures (MAP), and other various transfer pricing issues.

Key Services

Prepare transfer pricing reports
Assist with the application for advance pricing agreement (APA)
Provide representation in transfer pricing audits
Provide advice on foreign finance accounts

Representative Cases

Prepared the transfer pricing report for a Korean subsidiary of a foreign corporation
Prepared the advance pricing agreement for a foreign semiconductor company
Represented a Korean textile and apparel corporation in a transfer pricing audit
Prepared the transfer pricing report for a Korean subsidiary of a foreign corporation
Prepared the advance pricing agreement for a foreign semiconductor company
Represented a Korean textile and apparel corporation in a transfer pricing audit
Represented a foreign auto parts company in a tax audit involving permanent establishment issues
Advised majority shareholders of a domestic major corporation on U.S. FATCA compliance requirements
Represented a domestic major corporation in a tax audit relating to effective place of management
Prepared reports on allocation of intra-group service fees within a foreign group company