The global minimum tax was recently introduced in the Law for the Coordination of International Tax Affairs (“Pillar 2”). This introduction email was and summarized and prepared for a Multi-National Corporations with a subsidiary in the Republic of Korea.

The Pillar 2 applies to multinational entities with annual revenues exceeding EUR 750 million.

RSM KR Thought) Therefore, if you are well below the threshold, you can take a breath unless your entity significantly grows to be near the threshold.

Assuming that the group’s consolidated revenues exceed the threshold, you should principally prepare and file GloBE information return (GIR) to the Korean tax authorities. GIR shall include various and complex tax related information, but you could be exempt from filing the comprehensive GIR filing obligation in the Republic of Korea by filing one global GIT with either the Ultimate Parent Entity or A Designated Filing Entity.

If you are familiar with the Country-by-Country Report Notification filing, this is a very similar concept as you still file the GIR notification (the “GIRT”) form to the Korean tax authorities.

※ An important requirement for one global filing is that a "Qualifying Competant Authority Agreement" must be in effect by the filing deadline to exchange the GloBE information with the jurisdiction of the constituent entities.