Transfer Pricing Advisory

Our transfer pricing team is comprised of approximately 70 professionals with knowledge and experience across multidisciplinary fields, including accounting, tax, finance, economics, and law. As one of the largest dedicated transfer pricing practices in Korea, we offer innovative approaches to transfer pricing issues based on diverse backgrounds and extensive experience.

Transfer pricing is one of the most significant international tax issues facing multinational companies operating globally. Tax authorities worldwide require taxpayers to properly comply with transfer pricing regulations and maintain transparency in their transfer pricing policies. Consequently, multinational companies must establish and consistently implement transfer pricing policies while addressing continuous changes in economic conditions, transfer pricing regulations, and the tax environment.

We help clients to establish reasonable transfer pricing policies for diverse and complex intercompany transactions and assist in minimizing transfer pricing risks in advance, providing on-going support for tax audits and dispute resolution with tax authorities across multiple jurisdictions. As a member of the PwC global transfer pricing network, we are able to leverage worldwide resources and expertise to deliver the services our clients require for their various international transactions.


How can we support?

  • Transfer pricing policy design and operating-model advisory (transfer pricing planning)
  • BEPS documentation
  • Documentation of historical intercompany transactions
  • Transfer pricing risk assessments in preparation for domestic and overseas tax audits
  • Support for domestic and overseas transfer pricing audits and tax appeals
  • Assistance on Advance Pricing Agreements (APA) and Mutual Agreement Procedures
  • Business restructuring and the reallocation of functions and risks
  • Brand royalty policy design and documentation
  • Operational transfer pricing (SAP-based transfer pricing operating system) and transfer pricing monitoring (transfer pricing review, monitoring, and adjustment processes)
  • Other advisory services relating to intercompany transactions among domestic and overseas affiliates
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