Korea: Guidance regarding amendments to Pillar Two rules
The Ministry of Economy and Finance published regulations regarding the amendments to the Korean Pillar Two global minimum tax rules.
Guidance regarding amendments to Pillar Two rules
The Ministry of Economy and Finance (MOEF) on 27 February 2024 published regulations (effective as of 22 March 2024) regarding the amendments to the Korean Pillar Two global minimum tax rules enacted under the 2023 tax reform bill. Read TaxNewsFlash
The global anti-base erosion (GloBE) information return (GIR) form was also released as a part of the regulation, along with the GIR notification form and the top-up tax declaration form under the income inclusion rule (IIR). Information required for the GIR is consistent with data points from the standardized GIR released by the OECD in July 2023.
Next steps
The domestic GloBE rules are now fully enacted in Korea with detailed guidance on various topics included in the OECD GloBE model rules and commentary and February and July 2023 administrative guidance (AG).
It is expected that further amendments will be announced shortly to reflect the undertaxed payments rule (UTPR) safe harbor from the July AG as well as updates from the December 2023 AG.
An official announcement on the introduction of a qualified domestic minimum top-up tax (QDMTT) in Korea may follow.
Read an April 2024 report prepared by the KPMG member firm in Korea
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.