Korea: Proposed amendments to transfer pricing and Pillar Two rules
Proposed amendments to Korea’s transfer pricing and Pillar Two rules—generally effective for fiscal years beginning 1 January 2024
Proposed amendments to transfer pricing and Pillar Two rules
Proposed amendments to Korea’s transfer pricing and Pillar Two rules—generally effective for fiscal years beginning 1 January 2024—include:
- Change to Master file and Local file submission deadline
- Requirement to submit statement of overseas related-party transaction
- Exception to tax adjustment imposition period for change in global minimum tax rate
- Clarification of definition of permanent establishment
- Exemption criteria for global anti-base erosion (GloBE) rules according to qualified domestic minimum top-up tax (QDMTT)
- Special undertaxed payment rule (UTPR) provisions for multinational business groups in the early stages of overseas expansion
- Penalty exemption related to the GloBE top-up tax in the transitional period
- Exemption of penalty for errors in the GloBE information return in the transitional period
Read an August 2023 report [PDF 1 MB] prepared by the KPMG member firm in Korea
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