Korean Tax Newsletter 2011

• Samil Commentary 2011. 12
  
  This issue highlights selected changes to the government's tax reform proposals for 2011 including a lower adjustment of the newly proposed middle corporate income tax bracket. It also includes:
  - MOSF’s List of Laws to be Amended in 2012
  - Korea’s Social Security Agreement with India Entered into Force in November 2011
  - VAT Base in Case of Adjustment of Tax Amount based on the Arm’s Length Price
  - Payment for Software traded on on-line Open Markets to a Non-resident Having no PE in Korea Deemed as Korean Sourced Royalty Income
  - Initial Date of Reckoning Severance Pay in case of Merger of Companies having Different Severance Pay Schemes
  
  
• Samil Commentary 2011. 11
  
  - NTS Notice on Certificate of Good Standing and Tax Compliance
  - Guidance of Penalty Against non-compliance with Obligation to Submit Foreign Subsidiary Information
  - Korea to Tighten Disclosure Requirements of Inter-company Transactions in a Business Group
  - Korea, Ecuador Agree to an Income Tax Treaty
  - How to Pay Local Income Tax on the Payment of Corporate Income Tax Withheld by a Domestic Company on Behalf of a Foreign Company
  - Classification of Interest Payment Made by Parent Company for an Insolvent Subsidiary
  - Penalty for Non-Compliance with Requirement for Submitting International Transaction Information
  - Transaction Eligible for Zero-Rated VAT
  - Electronic VAT Invoice Reissued Based on Paper Invoice after the Filing Period
  
  
• Samil Commentary 2011. 9
  
  - Additional changes in Tax Reform Proposals for 2011
  
  
• Samil Commentary 2011. 9
  
  - Tax Reform Proposals for 2011
  
  
• Samil Commentary 2011. 8
  
  - Preliminary Return and Payment no Longer Required for Capital Gain on Shares Traded on Foreign Exchanges
  - Amended Education Tax Law Clarifies How the Income Amount of Banking and Insurance Businesses is Calculated
  - Korea to Sign Tax Information Exchange Agreements with British Virgin Islands and Costa Rica
  - Korea, Peru Agree to an Income Tax Treaty
  - Supreme Court Focuses on Substance over Form in a Korean Shipping Company’s Transaction through a Paper Company
  - Zero-rate VAT not Applicable to Domestically Supplied Goods for Export business Unless it meets the documentation requirements for VAT purpose
  - Requirements for Dividend Deduction of PFV
  
  
• Samil Commentary 2011. 6
  
  - Higher R&D Tax Credit for Core Technologies and Strategic Growth Industries
  - Proposed Bank Levy to be Enforced in August 2011
  - Advance Payment of Signing Bonus with Recourse Agreement
  - Barred Offset of Severance Payment against Unpaid Employee Loan
  - VAT Liability for Cybermall Transactions by Nonresident Trader
  - Tax Credit for Logistics Outsourcing Cost in a Spin-off
  - Tax Credit for Investment in Semiconductor Manufacturing Cleanroom
  
  
• Samil Commentary 2011. 4
  
  - Tax credit on third party logistics expenditure
  - R&D Tax Credit vs Investment Credit for R&D Facilities
  - Coupon Discounts Excluded from Taxable Base
  - Interim Payment of Retirement Benefits
  - Non-filing of Documents establishing Zero-rate VAT
  - NTS Advance Ruling on R&D Tax Credit
  - NTS Advance Ruling on Investment Credit
  - Treatment of Retroactive Payment of Salary Increases
  
  
• Samil Transfer Pricing Report 2011. 2
  
  This report highlights the latest amendments to the Law for the Coordination of International Tax Affairs, Korean tax regulations for international transactions which are generally applicable for fiscal years beginning on January 1, 2011. .Also, we are pleased to enclose the Korean edition of this publication. This report is published by Samil PricewaterhouseCoopers Transfer Pricing Practice.
  
  
• Samil Commentary 2011. 1