South Korea–MNE Tax

Asia-Pacific

Celltrion companies, others fined USD 12.5 million (KRW15.4 billion) in South Korean transfer pricing violations: Sarah Chea / Korea JoonAng Daily→

March 18, 2022

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

February 28, 2022

Asia-Pacific

South Korea to extend R&D tax incentives to technologies related to carbon neutrality, including carbon capture and renewable energy, as well as for rare earth elements facing supply shortages: Yonhap / The Korea Herald→

January 6, 2022

Asia-Pacific

Taiwan signs tax treaty with South Korea, seeks trade agreements with India and Australia: Lin Chia-nan / Taipei Times→

December 2, 2021

Americas

Asia to see disparate impacts from global digital tax reforms, IMF reports

September 15, 2021

Global tax reform efforts to address digitalization of the economy would likely have modest revenue effects in Asia, on the whole, according to a September 14 report from the International Monetary Fund; however, the effects would be uneven . . .

Asia-Pacific

South Korean tax revision bill includes incentives to spur economy

August 27, 2021

Ross Harman and Jeongwoo Park, Lee & Ko, discuss the July 26 Korean government’s proposed 2021 tax revision bill, including expanded tax reductions for start-ups, extended job creation tax credits, and enhanced research and development (R&D) tax credits, among . . .

Americas

Japan releases study group report on international taxation in the digital economy

August 19, 2021

Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Asia-Pacific

South Korean tax reform proposal includes enhanced R&D incentives

July 27, 2021

A tax reform bill introduced by the South Korean government on July 26 includes research and development (R&D) measures aimed at promoting . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Americas

US Senate approves bill with R&D funding for semiconductor industry

June 17, 2021

The US Senate passed with bipartisan support on June 8 a bill that would authorize new funding for research and development (R&D) to boost . . .

Asia-Pacific

South Korea expands R&D tax breaks to bolster semiconductor industry

June 2, 2021

The Republic of Korea signaled its intention to heavily boost its semiconductor industry with an announcement on May 13 that it will offer up to 50 percent tax credits on research and development (R&D) investment and up to 20 percent . . .

Americas

G7 reportedly close to deal on new rules for taxing multinationals

May 24, 2021

The G7 group of leading economies is getting close to an agreement to shake up the global rules on the taxation of multinational businesses . . .

Americas

Google UK reports its 2020 financials: the transfer pricing implications

April 28, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Google UK’s 2020 financial report . . .

Asia-Pacific

Netflix Korea reports its 2020 financials: transfer pricing implications

April 21, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Netflix’s new 2020 financial reporting in South Korea . . .

Asia-Pacific

Google Korea, Facebook Korea report income for the first time but in questionable sum: Hong Sung-yong & Minu Kim / Pulse→

April 14, 2021

Americas

US support for R&D has stalled relative to France, UK, others

April 14, 2021

While several countries have significantly boosted their support for business research and development (R&D) relative to their overall economies in recent years, total US government support for business R&D . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Asia-Pacific

Synthesized text of Australia–Korea tax treaty, as modified by the MLI published: Australian Taxation Office→

October 16, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

OECD publishes tax information exchange reviews for Anguilla, Chile, China, Gibraltar, Greece, Korea, Malta, Papua New Guinea, Uruguay: OECD→

September 3, 2020

Asia-Pacific

The Korean tax authorities’ challenge to Netflix’s transfer pricing

September 1, 2020

Dr. Harold McClure, a New York City economist, notes the Korean National Tax Service’s August 27 announcement that it is investigating the transfer pricing practices of 21 multinationals, including US technology and media multinational, Netflix, and considers what the tax service’s transfer pricing dispute with Netflix might be. . .

Asia-Pacific

South Korean tax office investigating Netflix over “phantom” management fees paid to US headquarters: Yonhap News Agency→

August 27, 2020

Asia-Pacific

South Korea auditing Starbucks’ tangible asset and service transaction transfer pricing: Hankyoreh→

June 8, 2020

Asia-Pacific

BEPS MLI to enter to force for Czech Republic, Korea

May 13, 2020

The OECD today announced that the Czech Republic and Korea have deposited their . . .

Asia-Pacific

New South Korea transfer pricing and diverted profits tax laws enter into effect

April 16, 2020

Jay Shim and Steve Minhoo Kim of Lee & Ko, South Korea, discuss important amendments to South Korea’s international tax and transfer pricing laws that became effective on January 1 including a Korean version of a diverted profits tax and new simplified transfer pricing rules for intra-group low value-adding services . . .

Asia-Pacific

Korea expands R&D tax credit, other technology tax incentives

February 11, 2020

Unghwan Rap Choi, Esq., Ph.D., Partner and International Tax Leader at CKP, LLP, Irvine, California, discusses new Korean government tax incentives offered for research and development . . .

Asia-Pacific

South Korea, Cambodia sign tax treaty: The Korea Herald→

December 5, 2019

Asia-Pacific

New South Korea tax chief promises to reduce investigations into company tax affairs: Yonhap News Agency→

July 2, 2019

Africa

Singapore, Korea sign tax updated treaty lowering withholding tax rates

May 13, 2019

The governments of Singapore and South Korea today signed . . .

Switzerland, South Korea sign tax treaty protocol

May 17, 2019

Switzerland and South Korea today signed a protocol to their 1980 tax treaty adding . . .

Asia-Pacific

South Korea approves bill imposing 10 percent VAT on technology companies: Pulse→

December 11, 2018

EU officials to recommend removal from tax blacklist for Panama, South Korea, UAE, Barbados, Grenada, Macao, Mongolia, Tunisia: Francesco Guarascio / Reuters→

January 16, 2018

Asia-Pacific

South Korea protests inclusion in EU tax blacklist: the hankyoreah→

December 7, 2017

Asia-Pacific

India-Korea tax treaty enters into force

October 27, 2016

A double tax treaty signed by India and Korea on May 18, 2015, entered into force on September 12, the government of India announced . . .

Asia-Pacific

Korea considers tax audit challenging low prices GM charged affiliate for autos: Kim Bo-gyung / The Korea Herald→

March 2, 2018

Asia-Pacific

India-Korea bilateral advance pricing agreements can include rollback, Indian tax board says

March 20, 2017

“Rollback” of a transfer pricing method to resolve disputes in previous open tax years is permitted for bilateral advance pricing. . . .

Asia-Pacific

Philip Morris fighting Korean tax authority over tobacco tax: Bae Hyun-jung / The Korea Herald→

July 25, 2018

Asia-Pacific

South Korea suspends plan to lower ownership threshold for withholding capital gains of share sales by foreigner investors: Yulchon LLC / Lexology→

February 12, 2018

More: Dahee Kim, Cynthia Kim / Reuters→

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Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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