GloBE Country Guide: South Korea

Summary

Status Enacted
LawOn March 22, 2024, the Enforcement Regulations to the International Tax Adjustment Act were amended for GloBE adjustments. This includes attachments for the GIR (in English and Korean) and the GloBE Tax Return.

On February 29, 2024, the Enforcement Decree to the International Tax Adjustment Act was amended to reflect aspects of the GloBE rules.

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.

On December 31, 2023, Law 19928 was issued to amend the International Tax Adjustment Act. .

On November 9, 2023, South Korea issued the Preliminary Legislative Notice of Partial Amendment to the Enforcement Decree of the International Tax Adjustment Act
Effective DateJanuary 1, 2024
IIRYes (2024)
UTPRYes (2025)
QDMTTNo
Filing DeadlinesStandard
Safe HarboursYes – Transposed from OECD Guidance

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties
  7. Sourcing South Korea’s GloBE Law to the OECD Model Rules

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