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Cross-border Tax Talks
July 12, 2023
Pillar Two in South Korea: Effective dates and much more
Doug McHoney (PwC's International Tax Services Global Leader) is at PwC’s AsiaPac Tax Symposium in Singapore. He is joined by Michael Kim, a PwC International Tax Partner and South Korea’s Outbound Tax Leader. Doug and Michael discuss South Korea’s enactment of Pillar Two, paying particular attention to effective dates, likely legislative actions, the incorporation of future guidance, how taxpayers are preparing for Pillar Two, Safe Harbours, data collection, and covered taxes.
Timestamps:
- 3:10 - Pillar Two was enacted in Korea in December 2022. What exactly was enacted and what are the effective dates?
- 5:00 - Can we expect the Korean tax administration to defer the application of the UTPR to 2025? When should we expect an announcement?
- 8:20 - Why did South Korea have to enact these rules in December 2022 for them to be effective in January 2024?
- 10:00 - How will South Korea incorporate the OECD guidance that has come out since enactment and the expected future guidance?
- 13:00 - How are South Korean taxpayers preparing for Pillar Two?
- 14:30 - How are tax departments generally structured in South Korea? Is it centralized? Decentralized?
- 15:20 - Are most companies in South Korea affected by International Tax Reform—Pillar Two Model Rules (IFRS) and how are they dealing with IAS 12 Income Tax?
- 17:15 - What is Michael seeing from a South Korean perspective with respect to Safe Harbours?
- 21:00 - What challenges does Michael see with regard to data collection?
- 25:00 - What is the general approach from Korean multinationals on covered taxes, particularly when they have to make investment decisions in the US?
- 27:45 - What advice does Michael have for South Korean taxpayers and taxpayers in the Asia-Pacific region?
Speakers
International Tax Services Global Leader, PwC US
Michael Kim
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