International transfer pricing update
In this quarterly webcast, moderator John Hobster and our panel of Ernst & Young professionals will discuss transfer pricing developments in Korea, advance pricing agreements (APAs) in Japan, and the impact of clustering on transfer pricing.
Transfer pricing developments in Korea
The discussion will include:
- Recent changes to the Korean transfer pricing regulations
- Dispute resolution for transfer pricing cases
- Overview of APAs in Korea
- Increase in tax audits for cross-border transactions
- Interface between transfer pricing and customs in Korea
Rap (Unghwan) Choi, Ernst & Young Han Young, Partner, Korea Transfer Pricing Leader.
Ins and outs of Japan APAs: focus on inbound taxpayers
Japan has a reputation as a tough transfer pricing jurisdiction, and foreign taxpayers in Japan need to actively manage their transfer pricing risk. Japan's long-established and efficiently managed APA program offers an effective way of getting certainty in this area. While the process is rigorous, the system works, as evidenced by steady year-on-year increases in the number of APA applications. We will discuss the mechanics of the process, as well as some common concerns about APAs in Japan.
Jon Jenni, Ernst & Young Executive Director, Transfer Pricing; Tokyo.
Impact of clustering on transfer pricing
As companies look to optimize their operating model (e.g., to drive efficiency and consistency), an increasing number of companies have centralized functions in geographic clusters. We will discuss the impact clustering has from a transfer pricing and permanent establishment perspective, and suggest how to address the issues that arise.
Peter Algar, Ernst & Young Director: London