Korea
1. Korea was reviewed as part of the 2017/2018 and the 2018/2019 peer reviews. This report is supplementary to those previous reports (OECD, 2019[1]) (OECD, 2018[2]).
2. The first filing obligation for a CbC report in Korea commences in respect of fiscal years commencing on or after 1 April 2016.
Summary of key findings
3. Korea’s implementation of the Action 13 minimum standard meets all applicable terms of reference (OECD, 2017[3]).
Part A: The domestic legal and administrative framework
4. Korea has legislation in place which implements the BEPS Action 13 minimum standard.
Part B: The exchange of information framework
(a) Exchange of information framework
11. As of 31 March 2020, Korea has 65 bilateral relationships in place, including those activated under the CbC MCAA and bilateral QCAAs. Within the context of its international exchange of information agreements that allow automatic exchange of information, Korea has taken steps to have qualifying competent authority agreements in effect with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions. Regarding Korea’s exchange of information framework, no inconsistencies with the terms of reference were identified.
References
OECD (2019), Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 2): Inclusive Framework on BEPS: Action 13, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://dx.doi.org/10.1787/f9bf1157-en. [1]
OECD (2018), Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 1): Inclusive Framework on BEPS: Action 13, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264300057-en. [2]
OECD (2017), Terms of reference for the conduct of peer review of the Action 13 minimum standard on country-by-country reporting, OECD Publishing, https://www.oecd.org/tax/beps/beps-action-13-on-country-by-country-reporting-peer-review-documents.pdf. [3]