The Korean company (hereinafter ‘MedImpo Corp’) imported medicines from foreign related parties and sold them locally. The tax authorities issued an assessment based on transfer prices between two unrelated comparable companies and then applied the resale price method to calculate the “normal price” on the imported medicines. MedImpo Corp argued that the selection of a comparable company by the taxation authority was unlawful. They held that the selected transactions between local companies were not comparable because MedImpo Corp purchased and sold goods from overseas related parties. The Korean Tax Tribunal ruled in favor of the tax authorities. “Even if the price is applied in transactions with foreign related parties, if the transaction is conducted at a price that is considered to be applied or applied in a normal transaction with a person who is not a related party, the price may be the normal price (meaning: In the case of calculating the normal price, the normal price range should be ... Read more