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International Tax Service

With CENTRIC’s accumulated expertise, we provide clear solutions to your international tax challenges.

Service Overview

As Korea has grown into a major trading nation, issues of double taxation across multiple jurisdictions have inevitably increased, imposing significant costs on businesses.

In response, the G20 and OECD have introduced measures to combat Base Erosion and Profit Shifting (BEPS), including requirements for transfer pricing documentation, which Korea has implemented since 2016. Companies must now provide extensive information on overseas investments, affiliates, financials, global operations, and related-party transactions—demanding considerable resources.

Unlike domestic tax issues, international tax matters cannot be resolved with knowledge of domestic law alone; they require expertise in foreign tax laws and tax treaties.

CENTRIC’s international tax team, composed of former National Tax Service (NTS) officials, foreign CPAs, and Korean CPAs, delivers premium, differentiated services for complex cross-border tax issues.

Service Process

CENTRIC’s TP audit team, led by former NTS examiners, ensures companies are not unfairly assessed.

- Consultation with client (understanding the specific situation)
- Preliminary review of tax issues (organization, business activities, financials)
- Development of solutions to minimize tax risks
- Delivery of solutions to client
- Representation before tax authorities, if required

Detailed Services
  • BEPS Compliance

    Preparation of transfer pricing documentation (Master File, Local File, Country-by-Country Report) in accordance with BEPS Action 8–10 and Korea’s International Tax Coordination Law.

    Ensuring that transfer pricing risks are minimized by reflecting industry characteristics and transaction types.

  • International Tax Advisory

    Outbound (Korean companies overseas) and inbound (foreign companies in Korea) tax advisory at investment, operation, and exit stages.

    Advisory on:
    - Permanent establishment taxation
    - Expatriate taxation
    - Withholding tax on interest, dividends, royalties, and capital gains
    - Other cross-border tax issues

  • Transfer Pricing (TP) Advisory

    Development of transfer pricing policies to allow businesses to focus on operations while minimizing tax risks.

    Services include:
    - Arm’s length pricing for goods, services, financing, and royalties
    - Transfer pricing documentation
    - APA (Advance Pricing Agreements) and MAP (Mutual Agreement Procedures)

  • Transfer Pricing Audit Support

    Assistance with audits where companies face:
    - Extensive requests for information on affiliates
    - Limited access to domestic and international databases
    - Challenges in rebutting arm’s length pricing proposed by tax authorities

Key Achievements

  • Prepared CBCR, Master File, and Local File for major conglomerates.

  • Successfully filed a correction claim for a listed company (Company B) by analyzing toll manufacturing service transactions with an overseas subsidiary.

  • Prevented tax assessments for a large metal manufacturer (Company C) by advising on goods and royalty transactions with foreign affiliates.

  • Provided TP advisory for a foreign apparel company (Company D) regarding royalty payments, preventing additional assessments.

  • Assisted a large manufacturer (Company E) in avoiding assessments on payments to overseas R&D centers for software development services.

  • Provided TP advisory for a game company (Company F) on non-listed foreign share transactions with affiliates, avoiding assessments.

  • Advised a pharmaceutical company (Company G) on drug transactions with foreign affiliates, preventing assessments.

  • Provided international tax advisory to a large company (Company H) regarding beneficial ownership issues, successfully preventing assessments.

  • Assisted a major corporation (Company I) in proving that its overseas subsidiary was not effectively managed from Korea, preventing assessments.

More +

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