GloBE Country Guide: South Korea

Summary

Status	Enacted
Law	On July 25, 2024, the Ministry of Economy and Finance issued the 2024 Tax Law Amendment Bill. This includes a number of amendments to the South Korean global minimum tax law to reflect aspects of the OECD Administrative Guidance. On March 22, 2024, the Enforcement Regulations to the International Tax Adjustment Act were amended for GloBE adjustments. This includes attachments for the GIR (in English and Korean) and the GloBE Tax Return. On February 29, 2024, the Enforcement Decree to the International Tax Adjustment Act was amended to reflect aspects of the GloBE rules. On December 31, 2022, South Korea passed Law 19191 to amend the International Tax Adjustment Act to provide for the Pillar Two Global Minimum Tax from January 1, 2024. On December 31, 2023, Law 19928 was issued to amend the International Tax Adjustment Act. . On November 9, 2023, South Korea issued the Preliminary Legislative Notice of Partial Amendment to the Enforcement Decree of the International Tax Adjustment Act
Effective Date	January 1, 2024
IIR	Yes (2024)
UTPR	Yes (2025)
QDMTT	No
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour and the QDMTT Safe Harbour. The Transitional UTPR Safe Harbour is included in the 2024 Tax Law Amendment Bill.

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties
Sourcing South Korea’s GloBE Law to the OECD Model Rules

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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