S-Space College of Business Administration/Business School (경영대학/대학원) Institute of Management Research (경영연구소) 경영논집 경영논집 vol.36 (2002)
이전가격결정에 관한 연구 - 조세측면을 중심으로 - : A Study on Transfer Pricing
- Issue Date
- 서울대학교 경영연구소
- 경영논집, Vol.36 No.2/3, pp. 753-770
- This study analyzed the international aspect of Korean tax law related to transfer pricing.
This study presented application examples of comparable uncontrolled price method, resale
price method and transactional net margin method through actual enterprises to see the
situations that these methods can be used as the Arms Length Price criteria.
The comparable uncontrolled price method was used in the case that the comparable
enterprise which sold similar products in similar markets was found. The resale price method
was applied in the case that the gross margin earned on purchases from foreign affiliated
supplier and the gross margin earned on purchases from unaffiliated supplier within the
tested company. The transactional net margin method was done in the case that more
credible methods such as comparable uncontrolled price method, resale price method could
not used. The transactional net margin method used operating asset margin as an appropriate
profit level indicator which was adjusted for differences in certain asset ratios between the
comparable companies and the tested corporation. Tax authorities and law courts can use the
results of this study as benchmark data of transfer pricing.
This study has the limits in that subjective assesment of the situations of companies might
be performed and generalization of research results is difficult.