Korea Issues Amendments to its Enforcement Decree for Pillar 2 Updates

On January 19, 2026, South Korea issued a Draft Law to amend the Enforcement Decree to the International Tax Adjustment Act. This provides for detailed provisions for the application of the QDMTT, as well as amendments to the Transitional CbCR Safe Harbour, and amendments from the January 2025 OECD Administrative Guidance.  The provisions are planned to generally apply for financial years commencing after January 1, 2026.

QDMTT Application

On December 23, 2025, Korea enacted Law No. 21215 (‘the Law’) to implement the 2026 Tax Reform. This includes a domestic minimum top-up tax (DMTT), which is intended to be a Qualified Domestic Minimum Top-Up Tax (QDMTT). Article 3 of the Supplementary provisions to the law provides that this applies to financial years from January 1, 2026.

The Law is relatively high-level and provides for the broad scope of the QDMTT. Many of the detailed rules of application are to be determined by a Presidential Decree.

The 2026 Draft Amendment to the Enforcement Decree provides some of these additional rules for the application of the QDMTT: