APAs on the rise in Korea
October 29, 2009
The number of completed advance pricing agreements (APA) has risen in Korea, according to figures released by the country’s tax authority.
The report by the National Tax Service shows that 30 new APAs were completed in 2008, compared to 20 in 2007.
The figures also state that 35 new applications for agreements were filed, 13 unilateral and 22 bilateral.
It was outlined that the average completion time for a unilateral APA was 18 months and 27 months for a bilateral agreement.
During 2008, figures showed that the transactional net margin method and operating margin methods were the method of choice for taxpayers.
Since 1997, 106 APAs have been completed, of which 78 have involved Korean taxpayers with foreign parents or affiliates and 28 have involved Korean parents with foreign subsidiaries.
Of the 30 APAs completed in 2008, 43% were concluded with the US, but the number of bilateral APA applications with China has steadily begun to rise.
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