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APA status in Korea / Sojong
2016_APA.pdf
2018.01.25 87691

According to the 2016 APA Annual Report, published on 19 January 2018 by NTS, the TNMM was used in 37 out of a total of 39 Advance Pricing Agreements (APAs) entered during 2016 under article 6 of the Adjustment of International Taxes Act. Of 379 APAs concluded by 2016, 340 cases (90%) used the TNMM. Of these, 182 cases used operating margin (84 unilateral APAs, 98 bilateral APAs) and 93 cases used the Berry ratio (29 unilateral APAs, 64 bilateral APAs) as profit level indicators.

Out of the total 379 cases concluded by the year 2016, 261 cases (69% of the total) were inbound transactions, and the remaining 118 cases (31%) were

outbound transactions. Most of the outbound cases were concluded through mutual agreement procedures with foreign tax authorities. As of December 31, 2016, the NTS concluded the most number of APAs with Japan with 103 cases, followed by the US with 99, the EU countries with 57 and China with 48.


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