KPMG Korea’s Transfer Pricing Services Group (“Transfer Pricing Division of KPMG TAX”) is the Korean member group of KPMG Global Transfer Pricing Services. The Transfer Pricing Division of KPMG TAX supports our invaluable clients through the management of their transfer pricing issues by route of diverse and comprehensive consulting services on issues such as compliance with tax treaties, domestic and international tax laws, domestic and international tax audits, double taxation disputes between countries, transaction structures, and the development of transfer pricing policy in accordance with the client’s business strategy.

Strategic Planning and Advisory Services under BEPS related Taxation

Since the implementation of BEPS (Base Erosion & Profit Shifting) action plan, the Transfer Pricing Division of KPMG TAX provides customized transfer pricing consulting services that meet each clients’ specific needs. The Transfer Pricing Division of KPMG TAX diagnoses domestic and international tax risks for their overseas business, and assists in establishing a consistent and transparent transfer pricing policy, as well as relevant management systems.

Transfer Pricing Study and Documentation

The Transfer Pricing Division of KPMG TAX assists with written requests for transfer pricing information, and conducts transfer pricing analyses and reports in order to respond to the tax authority, such as in the case of a tax audit. Also, we prepare transfer pricing documentation on a regular basis in order to comply with the tax authorities’ documentation requirements. Specifically, we assist to prepare the Master File, Local File, and Country by Country Reports, which have been implemented by the Korean Government in 2016, and assess the BEPS risks of the clients in advance to aid in building an effective strategy.

Double Taxation Prevention and Dispute Resolution

The Transfer Pricing Division of KPMG TAX helps clients mitigate unfair transfer pricing taxation and double taxation risk through systematic and professional consulting services, including responses to the competent authorities for APAs, MAPs, domestic and international tax audits, appeals, and authoritative interpretations.

Valuation & Specialized Industry Advisory Services

The Transfer Pricing Division of KPMG TAX provides transfer pricing analyses of payment guarantees, financial transactions such as interest on borrowing/loans, trademark royalties, technical royalties, as well as arm’s length price analyses for domestic and foreign related party transactions. We also provide differentiated consulting services through our team’s industry specialization, including financial services, electronics, automobiles, trading, heavy industry, and consumer goods.