On 2 April 2018, the South Korean National Tax Service has published a notice on certain changes including arm’s length price determination and APA procedures. In determining the arm’s length price, non-price transaction terms are also taken into account to improve the effectiveness of the transfer pricing method.
For tax years beginning before 1 January 2019, APA applications must be submitted with the relevant tax office no later than the end of the first taxable year in the specific period of taxable years the APA is to apply. For tax years beginning on or after 1 January 2019, APA applications must be submitted no later than the day before the first day of the first taxable year in the specific period of taxable years the APA is to apply.
