Under the 2015 Tax Revision Bill, Korea is planning to implement new transfer pricing reporting requirements for multinational enterprises, including a new report on international transactions. The contents of the report are based on the guidelines developed as part of Action 13 of the OECD BEPS Project, and include:
- A Local File - including details of related party transactions the local entity taxpayer is involved in; and
- A Master File - including the structure of the taxpayers group, loca…