After the global economic recession, the Korean tax authorities intensified their tax audits. To effectively defend against the tax authorities’ challenges, more taxpayers are considering the development of robust transfer pricing documentation or applying for an advance pricing arrangement, point-out Hwang Su Hyun, Ha Dong Hoon, Warren Chung and Ahn Sang Min of KPMG.
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A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR