An article by article analysis that sources all of the articles of the South Korean Pillar Two legislation (the original Law, Amended Law and Amended Enforcement Decree) back to the OECD Model Rules.

The Amended Enforcement Decree implements most aspects of the February and July 2023 OECD Administrative Guidance. Read our analysis.

On November 9, 2023, South Korea issued the Preliminary Legislative Notice of Partial Amendment to the Enforcement Decree of the International Tax Mediation Act.

On July 28, 2023, the South Korean government published the Partial Amendment Proposal for the International Tax Adjustment Act, to amend their Pillar Two law to (1) take account of a number of OECD amendments issued in their Administrative Guidance, and (2) delay the implementation of the UTPR until January 1, 2025.

On July 22, 2022, South Korea released a draft law to implement the OECD’s Pillar Two GloBE Rules (the ‘draft law’) in legislative notice 2022-128. Read our analysis.