Transfer Pricing

Samil PwC is the largest transfer pricing practice in Korea with more than 60 multi-disciplinary professionals experienced in accounting, tax, finance, and economics.

Transfer pricing has become one of the most significant international tax issues as revenue authorities around the world have intensified their scrutiny of transfer pricing arrangements and increased efforts around enforcement of compliance. Under this environment, one of the most important things companies need to do is establishing their transfer pricing policies properly and implement them to ensure that all regulatory requirements are met consistently. Our transfer pricing practice  stays abreast of changes and new regulatory developments in the transfer pricing and tax environment.

As a member of PwC global network with over 3,100 transfer pricing professionals deployed in more than 90 countries, we’re well positioned to advise companies on developing compliant, tax-efficient structures for domestic as well as foreign-invested companies, including development of transfer pricing policies, transfer pricing risk assessment as well as support on transfer pricing investigations and dispute resolution procedures.

How can we support?

  • Develop a transfer pricing policy and implementation plan (TP Planning)
  • Assist with BEPS documentation for head offices and overseas subsidiaries
  • Assist with documentation of cross-border transactions
  • Evaluate potential exposure risk of domestic and overseas transfer pricing audits
  • Assist with domestic and overseas transfer pricing audit and tax controversy
  • Help companies request Advanced Pricing Agreement (APA) and/or initiate Mutual Agreement Procedures (Competent Authority)
  • Assist with restructuring of transactions and the redistribution of functions and risks
  • Develop brand royalty policies and prepare documentation to defense the royalty policy
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