On 3 August 2026, Korea’s Ministry of Finance and Economy released its 2026 Tax Reform Proposal. Among its international tax measures are proposed amendments intended to implement significant elements of the OECD/G20 Inclusive Framework’s January 2026 Pillar Two Side-by-Side Package.
Download the Article-by-Article analysis at: South Korea Decree – PDF Analysis
On February 27, 2026, South Korea issued an amendment to its international tax adjustment decree to provide for detailed provisions for the application of its QDMTT.
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 and will also extend the Transitional CbCR Safe Harbour by 1 year (as provided in the January 2026 OECD Side-by-Side Package).
On December 23, 2025, Korea enacted Law number 21215 to implement the 2026 Tax Reform. This includes a QDMTT from January 1, 2026.
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South Koreas 2025 Tax Reform Proposal (announced on July 31, 2025), provides that a QDMTT will be applied from January 1, 2026.
South Korea’s amendment to the Enforcement Decree No. 35348 of February 28, 2025 and the Decree of the Ministry of Economy and Finance No. 1114 of March 21, 2025 provide for further aspects of the June 2024 OECD Administrative Guidance as well as additional top-up tax forms.
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