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ARTICLE · 23 JUNE 2016

Tax Developments South Korea

In line with the recommendations contained in the OECD BEPS report on Action 13, South Korea has adopted new documentation requirements of master file and local file for income years beginning on or after 1 January 2016.

Hong KongTax
  • In line with the recommendations contained in the OECD BEPS report on Action 13, South Korea has adopted new documentation requirements of master file and local file for income years beginning on or after 1 January 2016. Adoption of the country-by-country report will commence at a later stage after the government evaluates the legislation of other countries adopting the CbC requirement. The new master and local files reporting requirement is applicable to all domestic corporations and all foreign corporations with permanent establishments in Korea with:
  1. annual net sales from the domestic place of business in Korea greater than 100 billion KRW; and
  2. annual cross-border related-party transactions of a value greater than 50 billion KRW.

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