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Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services
Type: Regulatory update
Date: 2/25/2013

Korea - Proposed tax changes could affect head office-branch transactions

February 25: A proposed change (by “presidential decree”) could potentially affect the tax treatment of head office-branch office transactions.

Details of the proposal are expected to be announced soon by the Ministry of Strategy and Finance.

According to currently available information, the anticipated presidential decree would revise the tax treatment of head office-branch office transactions, as follows:

Current treatment	Proposed change
Current rules do not provide clear guidance as to deductibility issues and application of the transfer pricing principles for internal transactions between Korean branches and the overseas head offices of a foreign corporation.	In efforts to define the tax treatment and provide clearer guidelines, it would be proposed that the Korean tax treatment of transactions between a Korean branch and its overseas head office would reflect the international standards based on Article 7* of the OECD Model Tax Convention.

*Article 7 of the OECD Model Tax Convention generally provides that, in determining the profits of a permanent establishment, expenses—e.g., administrative expenses—incurred on behalf of or for the benefit of the permanent establishment will be allowed as tax deductions, regardless of the location where the expenses occurred.

KPMG observation

If this change to Korean taxation is made, as proposed, there may be potential opportunities for certain taxpayers to claim an additional tax deduction with respect to a multinational entity’s Korean branch—e.g., financial companies with appropriate filings such as advance pricing agreements (APAs), amended tax returns, etc.

For more information, contact a tax professional with KPMG's Global Transfer Pricing Services group:

Gil Won Kang

+82 22 11 20 907

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© 2013 KPMG International Cooperative ("KPMG International"), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.