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A Review of South Korea’s Pillar Two Amendments to its Enforcement Regulation

On March 22, 2024, the Decree of the Ministry of Economy and Finance No. 1048, to amend the Enforcement Regulations of the International Tax Adjustment Act entered into force.

The GloBE rules are implemented in South Korea, in three separate pieces of legislation:

  – International Tax Adjustment Act [Enacted January 1, 2024] [Law No. 19928, 2023. 12. 31.]
 
  – Enforcement Decree of the International Tax Adjustment Act [Enacted February 29, 2024] [Presidential Decree No. 34264, 2024.]
 
  – Enforcement Regulations of the International Tax Adjustment Act [Enacted March 22, 2024] [Decree of the Ministry of Economy and Finance No. 1048, 2024. 3. 22.]
 
The amended Enforcement Regulations provide for additional detail on a number of aspects that were not covered in the Enforcement Decree. It also implements a number of outstanding aspects of the OECD Administrative Guidance into domestic law.
 
Key Amendments

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Picture of Lee Hadnum

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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