Key implementation point
Large volume of R&D and investment tax credits; non-refundable credits reduce GloBE covered taxes and can depress ETR below 15%.
Implementation detail
- 01 South Korea enacted Pillar Two amendments effective 1 January 2024.
- 02 Korea-specific: extensive R&D and investment tax credits in place; non-refundable credits reduce covered taxes.
- 03 UTPR not enacted in first wave.
- 04 Special economic zones (Incheon Free Economic Zone, etc.): reduced-rate regimes may create QDMTT exposure.
- 05 National Tax Service (NTS) issued guidance on GloBE compliance and data filing requirements.
Enacted legislation
국제조세조정에 관한 법률 (Law on Coordination of International Tax Affairs — amended)
Track South Korea rules against your live MNE
In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.
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