On December 31, 2022 South Korea was the first country to enact domestic law to implement the Pillar Two GloBE rules from January 1, 2024.
We’ve had draft laws published by the UK, Switzerland, South Korea and the Netherlands as well as the adoption of the EU Global Minimum Tax Directive, but this is the first domestic tax law enacted to give effect to the global minimum tax.
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.
The previous draft law was not amended. See our review of the draft law at: Pillar Two: South Korea’s Draft Pillar Two Law.
Whilst the Safe Harbour provisions as announced by the OECD in December 2022 are not included in the enacted law, an enforcement decree is to be expected which will provide for the safe harbour rules.