Overview of Pillar Two (Global Minimum Tax) information return forms

In recent months, we have seen a growing number of questions from Multinational Enterprise (“MNE”) groups regarding the Pillar Two (Global Minimum Tax) regime. Introduced under the OECD/G20 Inclusive Framework, Pillar Two is designed to ensure that MNE groups are subject to a minimum level of corporate income tax, generally set at an effective tax rate of 15%, in each jurisdiction where they operate.

Korea has also implemented the Pillar Two regime through the Law for the Coordination of International Tax Affairs and its related Presidential Decree and Enforcement Rules. As a result, MNE groups meeting certain thresholds are subject to information reporting obligations and, where applicable, additional tax filing obligations related to the Global Minimum Tax.

General rule for global minimum tax information reporting

Where the Income Inclusion Rule (“IIR”) applies, the required filing forms are, in principle, the same regardless of whether the reporting is carried out by a Korean constituent entity or a foreign constituent entity. The following forms are generally required:

• GloBE Information Return (Form53 - Korea, Form54 - English)
• Additional Tax Return under the IIR (if applicable, Form 56)

Even if a foreign constituent entity is responsible for preparing or submitting the GloBE Information Return at the group level, Forms 53 and 54 are still generally required to be filed in Korea, unless the specific exception described below applies.

Exceptional application of Form 55

According to the current guidance by the Korean tax authorities, the submission of Form 55, instead of Forms 53 and 54, may be permitted only where all the following conditions are met:

• The GloBE Information Return has been properly filed under another jurisdiction by a foreign constituent entity of the MNE group.
• The jurisdiction in which the GloBE Information Return is filed is a signatory to the GIR MCAA with South Korea.
• Automatic annual exchange of information under the GIR MCAA is operational and recognized as effective between Korea and the relevant jurisdiction.

Practical considerations

When assessing whether Form 55 can be filed on a standalone basis (without submitting Forms 53 and 54), taxpayers should look beyond the formal existence of an information exchange agreement and confirm whether automatic exchange is actually implemented and functioning in practice.

These requirements are not yet finalized, and further clarification from the Korean tax authorities is expected. At this stage, additional official guidance is anticipated before June 2026. Taxpayers are therefore encouraged to receive tax specialists’ advice when preparing their filings.

This overview focuses on the IIR–related information reporting framework under the Global Minimum Tax regime. Guidance on the Undertaxed Profits Rule (“UTPR”), including its filing requirements and practical issues, will be addressed separately in a future update.