Korea: 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