| THE LAW FOR THE CORDINATION OF INTERNAITONAL TAX AFFAIRS | |||||||||||
| 1. Transfer Pricing Regime | |||||||||||
| 2. Thin Capitalization Rules | |||||||||||
| 3. Anti-Tax Haven Rules | |||||||||||
| 4. Gift Tax on Property Located Outside Korea | |||||||||||
| 5. Mutual Agreement Procedure (MAP) | |||||||||||
| 6. International Tax Cooperation | |||||||||||
| 1. Transfer Pricing Regime | |||||||||||
| a. Adjustment of a Transfer Price Based on an Arm's Length Price | |||||||||||
| The LCITA (Law for the Coordination of International Tax Affairs) authorizes the tax | |||||||||||
| authorities to adjust the transfer price based on an arm's length price (ALP) and to | |||||||||||
| determine or recalculate a resident's taxable income when the transfer price of a | |||||||||||
| Korean company and its foreign counterpart is either below or above an arm's length | |||||||||||
| price. | |||||||||||
| (1) Special Relationship | |||||||||||
| The LCITA and its Decree recognize "special relationship" under the following | |||||||||||
| circumstances: | |||||||||||
| (Equity Ownership Test) | |||||||||||
| - where a foreign company directly or indirectly owns 50% or more of the voting | |||||||||||
| shares of a Korean company; | |||||||||||
| - where a Korean company directly or indirectly owns 50% or more of the voting | |||||||||||
| shares of a foreign company; | |||||||||||
| - if a corporation (or an individual), which directly or indirectly owns 50% or more | |||||||||||
| of the voting shares of a foreign company, directly or indirectly holds 50% or more | |||||||||||
| of the voting shares of a Korean company; and | |||||||||||
| (Substantial Control Test) | |||||||||||
| - if a company's ("Company A") representative director is employed by another | |||||||||||
| company ("Company B"), if 50% or more of Company A's directors are employed | |||||||||||
| by Company B, or if a substantial part of Company A's business is dependent | |||||||||||
| upon Company B's operating funds, intangible property rights, guarantees of | |||||||||||
| payments, or other transactions, then Company A's business policy will be | |||||||||||
| regarded as substantially influenced by Company B. | |||||||||||
| (2) Computation of Indirect Ownership | |||||||||||
| If company A owns a 50% stake or more in company B, and B owns a certain | |||||||||||
| percentage of shares in a third company C, B's equity ratio in C would constitute | |||||||||||
| the ratio of equity which A indirectly owns in C. | |||||||||||
| If company A owns less than a 50% stake of company B, and B owns a certain | |||||||||||
| percentage of shares in a third company C, then A is considered to own C to the | |||||||||||
| extent of the ratio computed by multiplying A's equity ratio in B with B's equity ratio | |||||||||||
| in C. | |||||||||||
| b. Criteria and Procedure for Transfer Price Adjustments | |||||||||||
| The LCITA and its Decree define an arm's length price (ALP) as a price that is | |||||||||||
| established or that can be expected to be established in a normal transaction | |||||||||||
| between independent enterprises without a special relationship. | |||||||||||
| The LCITA lists the following methods for determining an ALP: the comparable | |||||||||||
| uncontrolled price (CUP) method, the resale price method, and the cost-plus | |||||||||||
| method. Furthermore, the Decree elaborates upon the profit-split method and the | |||||||||||
| transactional net margin method (TNMM) as methods for determining an ALP based | |||||||||||
| on profits arising from controlled transactions. | |||||||||||
| The CUP method evaluates an ALP by comparing the price that an independent | |||||||||||
| uncontrolled person under the same or similar circumstances in terms of trade | |||||||||||
| conditions or volume would set for goods identical to those in question. | |||||||||||
| The resale price method may be applied where a manufacturer sells its products to | |||||||||||
| a related person and the related person resells the same product to an unrelated | |||||||||||
| third party without any further processing. Under this method, the adjustment in the | |||||||||||
| transfer price between related parties may be computed by subtracting an | |||||||||||
| appropriate mark-up amount from the price that the related reseller charges the | |||||||||||
| product to unrelated third parties. | |||||||||||
| The cost plus method, in principle, may be applied where a manufacturer sells his or | |||||||||||
| her products to the related party and the related party then adds value to the product | |||||||||||
| by processing it further to sell to unrelated third parties. In such cases, the ALP is | |||||||||||
| calculated as the price of the refined goods, less the actual costs of further | |||||||||||
| processing, together with an appropriate mark-up upon such costs. | |||||||||||
| The profit split method determines an ALP by taking the sum of profits earned by the | |||||||||||
| related parties and allocating them in proportion to the respective contribution | |||||||||||
| towards generating the profits realized. | |||||||||||
| Finally, the TNMM evaluates an ALP by first seeking an independent third company | |||||||||||
| which is similar to the company at issue in terms of its business operations and the | |||||||||||
| nature of its business, and then by subjecting such a company to functional and | |||||||||||
| comparability analyses. The income earned by the third company is then estimated | |||||||||||
| based upon the following ratios: profits to assets, operating profits to turnovers, and | |||||||||||
| profits to equity. These estimates will then be used to evaluate and if necessary, | |||||||||||
| adjust the income and profit of the related parties. | |||||||||||
| c. Selection of Method for Determining ALP | |||||||||||
| The Decree states that an ALP should be determined by the most reasonable method | |||||||||||
| applicable to the situation, whether it be the CUP method, the resale price method, | |||||||||||
| the cost plus method, or any other method. | |||||||||||
| The Decree sets out the following criteria for selecting the most reasonable method. | |||||||||||
| - | The level of comparability between the transactions of related parties and those of | ||||||||||
| independent parties must be high. | |||||||||||
| - | Sufficient data on a comparable independent party must exist. | ||||||||||
| - | The economic assumptions made in comparing the related parties' transactions | ||||||||||
| with those of independent parties must reflect the actual economic situation of the | |||||||||||
| parties. | |||||||||||
| The degree of comparability can be evaluated on the following factors: | |||||||||||
| - | functions performed and risks assumed, as reflected in conditions and | ||||||||||
| transactions; | |||||||||||
| - | types as well as characteristics of the goods or services involved; and | ||||||||||
| - | economic environment of the market and the degree of change in market | ||||||||||
| conditions. | |||||||||||
| If the inter-company price established by a Korean company and its foreign related | |||||||||||
| party differs from an ALP, the Korean company shall pay the corporate income tax | |||||||||||
| based upon the income it would have reported under an ALP. | |||||||||||
| If there is a transaction between unrelated parties identical or similar to the | |||||||||||
| transactions between the related parties at issue, the CUP method will be selected | |||||||||||
| over any other method. | |||||||||||
| Among the methods of determining an ALP, traditional transaction methods (i.e., the | |||||||||||
| CUP method, the resale price method, and the cost-plus method) have priority over | |||||||||||
| transactional profit methods such as the profit split method or the transactional net | |||||||||||
| margin method. The latter methods are intended to be used only if the traditional | |||||||||||
| methods are inapplicable. | |||||||||||
| If an international transaction made between unrelated parties cannot be treated as | |||||||||||
| an arm's-length transaction because of the possibility of price manipulation, such | |||||||||||
| transaction may not be used as a comparable one. | |||||||||||
| The tax authorities may use an arm's length range determined by two or more | |||||||||||
| uncontrolled transactions to adjust the taxable income of taxpayers. Such tax | |||||||||||
| adjustment must be made based upon reasonable values computed from the | |||||||||||
| transactions examined. | |||||||||||
| d. Reporting Methods for an ALP Determination | |||||||||||
| The method used and the reason for adopting that particular one for an ALP | |||||||||||
| determination must be disclosed to the tax authorities by a taxpayer in a report | |||||||||||
| submitted along with his annual tax return. | |||||||||||
| If the inter-company price used by a Korean company and its foreign counterpart | |||||||||||
| differs from the transfer price determined under the proper method for determining an | |||||||||||
| ALP, then the taxpayer must adjust such inter-company price. | |||||||||||
| e. Advance Pricing Arrangement (APA) System | |||||||||||
| If a taxpayer wishes to obtain an APA for transactions with its foreign related parties, | |||||||||||
| then he or she should submit an application for an APA to the National Tax Service | |||||||||||
| (NTS) by the end of the first fiscal year concerned. Both the NTS and the taxpayer | |||||||||||
| are bound by the method agreed upon in the APA. | |||||||||||
| Once the NTS approves the application of a certain method for determining an ALP, | |||||||||||
| the approved method is applicable for as long as the taxpayer desires. | |||||||||||
| An applicant for an APA may withdraw his application for an APA or change the | |||||||||||
| contents of such an application. | |||||||||||
| Any data submitted with the application for an APA will be used to only determine | |||||||||||
| whether or not to grant an APA. If an application for an APA is refused or withdrawn, | |||||||||||
| such data will be returned to the applicant in order to safeguard the confidentiality | |||||||||||
| right of the taxpayer. | |||||||||||
| In the case where an APA is obtained, a taxpayer is required to file an annual report | |||||||||||
| which shows the inter-company price which was determined by the method agreed | |||||||||||
| upon under the APA within six months of the annual tax return submission due date. | |||||||||||
| A taxpayer who applies for an APA may request that the NTS invoke a Mutual | |||||||||||
| Agreement Procedure (MAP) with the competent authorities of the country in which its | |||||||||||
| related foreign party is a resident under the relevant tax treaty (Bilateral APA). | |||||||||||
| However, the NTS may grant an APA without undergoing a MAP for the taxpayer's | |||||||||||
| convenience. | |||||||||||
| Having obtained an APA, a taxpayer may file an amended tax return that reflects the | |||||||||||
| change from its prior inter-company price with a related party and the price | |||||||||||
| determined under the APA. | |||||||||||
| f. Secondary Adjustment | |||||||||||
| If the tax authorities adjust the transfer price between a Korean company and its | |||||||||||
| foreign related party based upon an ALP, or if they increase the taxable income of the | |||||||||||
| Korean company, an amount equal to the additional taxable income will be treated as | |||||||||||
| dividends, contribution of paid-in capital, etc., unless the foreign party returns an | |||||||||||
| amount equivalent to the amount of adjustment to the Korean company. | |||||||||||
| If a foreign related party owns 50% or more of the voting shares of a Korean | |||||||||||
| company, an amount equal to the additional taxable income will be treated as | |||||||||||
| dividends paid out to the related party. If a Korean company owns 50% or more of the | |||||||||||
| voting shares of a foreign related party, an amount equal to the additional taxable | |||||||||||
| income will be treated as the Korean company's contribution to the foreign related | |||||||||||
| party as paid-in capital. | |||||||||||
| A Korean company will be deemed to have loaned an amount equivalent to the | |||||||||||
| additional taxable income to the foreign related company as of the last day of the | |||||||||||
| taxable year in which the inter-company transactions took place. The Korean | |||||||||||
| company is to include the deemed interest on the loan as taxable income. | |||||||||||
| g. Corresponding Adjustment | |||||||||||
| The LCITA and its enforcement decree state that if a foreign government, on the basis | |||||||||||
| of an ALP, increases the taxable income of a foreign company which is an | |||||||||||
| associated enterprise to its Korean Counterpart, the Korean government will | |||||||||||
| correspondingly reduce the taxable income of that Korean company if the two | |||||||||||
| governments have agreed upon an ALP applicable to the case through a Mutual | |||||||||||
| Agreement Procedure (MAP). In such a case, a taxpayer may apply for a downward | |||||||||||
| adjustment in his taxable income by filing a notification of the MAP results with the tax | |||||||||||
| authorities. | |||||||||||
| h. Sanctions imposed for Failure to Comply with the Data Request | |||||||||||
| Under the LCITA, the tax authorities are empowered to request from a taxpayer the | |||||||||||
| data required for an adjustment of the inter-company price. If a taxpayer fails to | |||||||||||
| submit the requested data within 60 days without any justification, the tax authorities | |||||||||||
| may grant an extension of 60 days. The taxpayer may appeal within 30 days of the | |||||||||||
| penalty imposition date. | |||||||||||
| The tax authorities may request the following data from a taxpayer: | |||||||||||
| - a copy of the sales contract between the Korean company and its foreign | |||||||||||
| counterpart; | |||||||||||
| - a price list of the products at issue; | |||||||||||
| - a schedule of the manufacturing cost of the products; | |||||||||||
| - an organizational chart of the company with a description of the functions of each | |||||||||||
| department; | |||||||||||
| - the inter-company price policy; and | |||||||||||
| - the equity relationship of the group. | |||||||||||
| 2. Thin Capitalization Rules | |||||||||||
| a. Outline of Thin Capitalization Rule | |||||||||||
| A multinational enterprise (MNE) may adopt a tax avoidance mechanism under which | |||||||||||
| the contribution of paid-in capital to its subsidiary in Korea is decreased, while | |||||||||||
| increasing its loans to the subsidiary as much as possible. This may result in the | |||||||||||
| minimization of the taxable income of the subsidiary through the increase in interest | |||||||||||
| expense deduction of the subsidiary. Under such an arrangement, non-deductible | |||||||||||
| dividend payments are replaced with deductible interest payments. | |||||||||||
| To cope with such an arrangement, the LCITA and its enforcement decree contain | |||||||||||
| thin capitalization rules; whereby if a Korean company borrows from its controlling | |||||||||||
| shareholders overseas (CSO), an amount greater than three times its equity (six | |||||||||||
| times in case of financial institutions) interest payable on the excess portion of the | |||||||||||
| borrowing, computed as shown below, will not be deductible in computing taxable | |||||||||||
| income. | |||||||||||
| For purposes of the thin capitalization rules, money borrowed from a CSO includes | |||||||||||
| amounts borrowed from an unrelated third party based upon the CSO's guarantee. | |||||||||||
| The following is the formula for computing non-deductible interest: | |||||||||||
| ¡¡ | Non-deductible interest = Interest and discount payable to CSO * B/A | ||||||||||
| ¡¡ | A : Debt borrowed from the CSO or guaranteed by the CSO; | ¡¡ | |||||||||
| ¡¡ | B : A - [Paid-in capital contributed by the CSO * 3 (or 6 in the case of a | ||||||||||
| ¡¡ | financial institution)]. | ¡¡ | |||||||||
| b. Debt Under an Arm's Length Situation | |||||||||||
| Although the ratio of debt owed to a CSO to equity exceeds 3:1, as long as the | |||||||||||
| conditions and the amount of debt owed to a CSO are reasonable compared to the | |||||||||||
| debt from an independent third party, such debt from the CSO will be excluded from | |||||||||||
| the scope of the debt subject to thin capitalization rules. As a result, interest on such | |||||||||||
| debt will be deductible. | |||||||||||
| Anti-thin capitalization that originated from the arm's length principle is adopted from | |||||||||||
| Article 9(1) of the OECD Model Tax Convention. Thus, if given requirements are | |||||||||||
| satisfied, the debt-equity ratio prevailing in the industry (rather than a 3:1 or 6:1 ratio) | |||||||||||
| will be applied. | |||||||||||
| 3. Anti-Tax Haven Rules | |||||||||||
| a. Outline of Anti-Tax Haven Rules | |||||||||||
| Under the LCITA and its enforcement decree, if a Korean company invests in a | |||||||||||
| company located in a tax haven, which unreasonably has reserved profits in the | |||||||||||
| controlled foreign company, the profits reserved therein shall be treated as dividends | |||||||||||
| paid out to that Korean company, despite the fact that the reserved profits are not | |||||||||||
| actually distributed. | |||||||||||
| Korean companies subject to anti-tax haven rules are companies directly or | |||||||||||
| indirectly owning 50% or more of the shares in a foreign company, or those | |||||||||||
| substantially controlling the business policy of the foreign company and owning at | |||||||||||
| least 20% or more of the voting shares. | |||||||||||
| Anti-tax haven rules are intended to regulate a company that has made overseas | |||||||||||
| investments of an abnormal nature. Thus, these anti-tax haven rules apply to those | |||||||||||
| Korean companies that have invested in a company incorporated in a foreign country | |||||||||||
| with an average effective tax rate of 15% or less on taxable income for the past three | |||||||||||
| years (previously it was one year). | |||||||||||
| However, if a company incorporated in such a tax haven country actively engages in | |||||||||||
| business operations through an office, shop, or a factory, then anti-tax haven rules | |||||||||||
| will not apply. | |||||||||||
| b. Scope of Actually Accrued Income | |||||||||||
| If an average effective tax rate imposed for the past three years by a foreign country | |||||||||||
| is 15% or less of the actually accrued income of a company incorporated therein, the | |||||||||||
| country will be classified as a tax haven. | |||||||||||
| The term "actually accrued income" refers to the net income before tax calculated | |||||||||||
| based on the generally accepted accounting principle (GAAP) of the host country. If | |||||||||||
| the host country's GAAP is significantly different from that of Korea, the actually | |||||||||||
| accrued income will be computed pursuant to the Korean GAAP. | |||||||||||
| c. Scope of a Tax Haven | |||||||||||
| According to the LCITA and its Decree, a country that meets any of the following | |||||||||||
| conditions is regarded as a tax haven. | |||||||||||
| - a country which does not impose a corporate income tax or which allows a tax | |||||||||||
| ¡¡ | exemption of 50% or more of actually accrued income | ¡¡ | |||||||||
| - a country whose average effective tax for the past three years is 15% or less of | |||||||||||
| ¡¡ | actually accrued income (i.e., net income before corporate income tax computed | ||||||||||
| ¡¡ | based on GAAP) of a company incorporated therein | ¡¡ | |||||||||
| For this purpose, if the company has paid foreign taxes, such foreign taxes will be | |||||||||||
| deemed to have been paid to the resident state. | |||||||||||
| Effective tax rate = (Tax paid to resident country £« Foreign taxes paid) | ¡¡ | ||||||||||
| ¡¡ | ¡¡ | / Net income before corporate income tax. | ¡¡ | ||||||||
| d. Computation of the Reserved Income to be distributed | |||||||||||
| The reserved income that can be distributed is computed by subtracting the items | |||||||||||
| listed below from the adjusted amount of earned-surplus. The earned-surplus is | |||||||||||
| represented on the income statements prepared in accordance with the GAAP of the | |||||||||||
| resident state of the foreign company subject to the anti-tax haven system: | |||||||||||
| - distribution of earned-surplus based upon an appropriation of retained earnings, | |||||||||||
| - bonuses, severance pay, and other types of outlays paid based on the | |||||||||||
| appropriation of retained earnings, | |||||||||||
| - reserves to be retained under the law of the resident state, and | |||||||||||
| - reserves remaining after the distribution of the earned-surplus for the year, which | |||||||||||
| was subject to tax in the previous taxable years. | |||||||||||
| If the resident state's GAAP is significantly different from the Korean GAAP, the | |||||||||||
| earned-surplus shall be computed pursuant to the Korean GAAP. | |||||||||||
| 4. Gift Tax on Property Located Outside Korea | |||||||||||
| Under the current Inheritance and Gift Tax Law (IGTL), a gift tax is imposed only if 1) | |||||||||||
| the donee is domiciled in Korea or 2) the donated property is located in Korea. | |||||||||||
| Accordingly, if a Korean individual donates a property located offshore to a donee | |||||||||||
| domiciled offshore, a Korean gift tax cannot be levied. In this case, moreover, if the | |||||||||||
| foreign country in which the donee is domiciled does not impose a gift tax, then | |||||||||||
| double non-taxation will occur. Korea, which is now a member of the OECD, intends | |||||||||||
| to adopt the "taxation of donor" principle of the OECD Model Double Taxation | |||||||||||
| Convention on Estates and Inheritances and on Gifts. | |||||||||||
| Under the LCITA and its enforcement decree, if a person domiciled in Korea donates | |||||||||||
| offshore property to a person who is domiciled in a foreign country where a donee is | |||||||||||
| not subject to a gift tax, the donor will be subject to the Korean gift tax. | |||||||||||
| 5. Mutual Agreement Procedure (MAP) | |||||||||||
| If a Korean resident requests that his case be resolved by recourse to the competent | |||||||||||
| authorities under an applicable tax treaty, the Minister of Finance and Economy or the | |||||||||||
| Commissioner of the National Tax Service shall invoke the mutual agreement procedures | |||||||||||
| (MAP). The MAP will be invoked in the following cases: | |||||||||||
| - | where it is necessary for Korea to consult with a foreign competent authorities with | ||||||||||
| respect to the application and interpretation of the tax treaty; | |||||||||||
| - | where a Korean resident is subject to taxation in a foreign country contrary to the tax | ||||||||||
| treaty concerned; or | |||||||||||
| - | where it becomes necessary for the competent authorities of the two countries to | ||||||||||
| adjust the taxable income of a taxpayer. | |||||||||||
| Once the MAP is invoked, the taxpayer will be allowed to postpone the filing of an appeal | |||||||||||
| until the MAP is completed. Furthermore, if the MAP is invoked under an applicable tax | |||||||||||
| treaty, the collection of national and local taxes will be postponed on a reciprocal basis | |||||||||||
| until the MAP is completed. | |||||||||||
| 6. International Tax Cooperation | |||||||||||
| The LCITA and its enforcement decree accept the general principle that income | |||||||||||
| classification under a Korean tax treaty takes priority over that of the domestic tax law. | |||||||||||
| Under the LCITA and its enforcement decree, the Korean tax authority may request the | |||||||||||
| tax authority of a treaty partner to collect the Korean taxes, subject to any limitations | |||||||||||
| provided for in the treaty. Similarly, if the treaty partner requests the Korean tax authority | |||||||||||
| to cooperate in collecting its taxes from a Korean resident, the Korean tax authority may | |||||||||||
| collect the treaty partner's tax in accordance with the procedure for the collection of | |||||||||||
| national taxes provided in the National Tax Collection Law. | |||||||||||
| The Korean tax authority may exchange tax information with foreign countries with which | |||||||||||
| Korea has entered into tax treaties, subject to the provisions and limitations of the tax | |||||||||||
| treaties. | |||||||||||
| If necessary, the Korean tax authority is permitted to 1) simultaneously conduct a tax | |||||||||||
| audit with foreign tax authorities concerned, under the convention for cooperation in tax | |||||||||||
| administration with that foreign country or 2) dispatch Korean tax officials to the | |||||||||||
| concerned foreign country to conduct a direct tax audit of the company in that country. | |||||||||||