Transfer Pricing
From transfer pricing documentation for multinational corporations to tax audit defense
and Advance Pricing Agreement (APA) negotiations, we support all aspects of transfer pricing.
Overview
Transfer pricing concerns the appropriateness of prices in transactions between related parties within a multinational group, and is the international tax issue most frequently disputed in National Tax Service audits. A coherent understanding of both the OECD Transfer Pricing Guidelines and domestic tax law is fundamental.
Led by specialists with National Tax Service international tax audit experience, PYEONG AN supports the entire transfer pricing lifecycle, including TP documentation, arm's length price calculation method selection, transfer pricing audit defense, Advance Pricing Agreement (APA) applications and negotiations, and Mutual Agreement Procedure (MAP) representation.
Key Practice Areas
- Transfer pricing documentation (Master File, Local File, CbCR) preparation
- Arm's length price calculation method selection and economic analysis
- Transfer pricing tax audit defense
- Advance Pricing Agreement (APA) application and negotiation representation
- Mutual Agreement Procedure (MAP) representation
- Transfer pricing tax appeal and litigation