Transfer Pricing

Transfer pricing is one of the most important international tax issues facing multinational companies doing business in Korea. Our multidisciplinary team of professionals has been involved in some of the largest and most complex transfer pricing audits and dispute resolution in Korea. Our dedicated transfer pricing practice has prepared studies that cover a wide range of inter-company transactions and can help clients with documentation to defend their transfer pricing data. In addition, our transfer pricing practice has accumulated significant experience helping clients obtain Advance pricing agreements (APAs).

Samil PwC has the largest transfer pricing practice in Korea. We provide a full range of transfer pricing services on inbound and outbound transactions and serve foreign companies doing business in Korea as well as Korean companies doing business overseas.

Our transfer pricing services include:
 

• Documentation of transfer pricing policies and compliance
• Risk assessment of taxpayer’s potential risk exposure in advance of a transfer pricing audit
• Assistance on transfer pricing audit defense and appeals
• Litigation support
• Advance pricing agreements
• Competent authority negotiations
• Planning/restructuring