Transfer Pricing under the New BEPS Paradigm: A Korean Perspective

In this article, the author considers how BEPS Actions 8, 9, 10 and 13 impact upon Korea’s transfer pricing law and practice. The article examines existing Korean transfer pricing legislation and case law, and focuses on the arm’s length principle and risks, intangibles, low value-adding intra-group services and cost contribution arrangements, from a Korean perspective.