The South Korean PE Risk Under Pillar Two

flag of South Korea

With the enactment of the Pillar Two GloBE Rules in South Korea from January 1, 2024, the costs of an unintentional permanent establishment (PE) in South Korea may be significantly greater. 

Data Points for Pillar Two Corporate Structures

corporate structure and Pillar Two Data Points

The GloBE Information Return will require information on an MNEs corporate structure in so far as it impacts the application of the Pillar Two GloBE rules. In this article we look at the data points that are required to comply with this.

UPE Data Points for the GloBE Information Return

QDMTT Design Features

In this first of a series of articles that will break down all of the data points for the purposes of the Pillar Two GloBE rules (and in particular the expected reporting in the GloBE information return), we look at the UPE data points in the corporate structure.