Korean Transfer Pricing Regulations and Income Tax Changes for Non-Residents

Codification of the “Substance over Form” Rule


Recently, the Ministry of Government Legislation announced significant amendments to the regulations of the Law for the Coordination of International Tax Affairs (LCITA) which regulate international transactions. The primary reasons for revising the LCITA are to prevent tax evasion through the codification of the “substance over form” rule, improve consistency with globally accepted taxation guidelines and promote the overseas investments of Korea based companies.



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