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Update - South Korea Tax Amendments for 2020 Including Substance Over Form Rules, Transfer Pricing Rules, and MAP

|Approved Changes|Korea, Rep of
Korea, Rep of

As previously reported, South Korea's National Assembly approved legislation for several tax amendments in 2020 at the end of December 2019. Additional information on the changes has become available, summarized as follows:

Substance Over Form Rules for Step Transactions

One of the important changes approved from 2020 are new rules that shift the burden of proof to a taxpayer that makes use of a step transaction that reduces its Korean tax liability and shifts profits to a low or no tax ju…

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