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South Korea × Tax & International Structuring
Tax & International Structuring in South Korea
Tax and structuring for businesses, investments and deals that cross borders. In South Korea, that means local law, local regulators and local practice, handled by a qualified professional who practises there.
Who handles this work
On request
WONE Global can find the right Tax & International Structuring professional in South Korea for you.
No WONE Global Partner holds this yet. Send us your requirement: WONE Global confirms whether a vetted Associate firm can act, tells you who it is and checks for conflicts before any work begins.
Bring a requirement →South Korea at a glanceEast Asia
Seoul · Wednesday 4 November
05:52
Local time
- Currency
- KRW
- Working week
- Monday – Friday
- Dialling code
- +82
- Region
- East Asia
What the rules say in South Korea
Tax & International Structuring, the essentials
From the South Korea market guide: the points that matter most for tax & international structuring, each with the source it was checked against.
Essentials guide · Source-checked research100% of statements checked against a source10 checked against an official source35 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed
A branch of a foreign company must appoint a representative and register with the court, while a liaison office may carry out only non-sales functions and does not need court registration.
Branches are treated as permanent establishments for tax.Enterprise Singapore · checked 2026-10-19Corporate income tax is charged at 10 percent on the first KRW 200 million of taxable income, 20 percent up to KRW 20 billion, 22 percent up to KRW 300 billion and 25 percent above that.
Fiscal years starting on or after 1 January 2026; excludes local income tax.PwC Worldwide Tax Summaries · checked 2026-10-19Local income tax is added at rates equal to 10 percent of the corporate tax rates, from 1.0 percent to 2.5 percent, giving a top combined marginal rate of 27.5 percent.
PwC Worldwide Tax Summaries · checked 2026-10-19Dividends, royalties and general interest paid to non-resident companies are subject to 20 percent withholding tax, or 22 percent including local income tax, unless a treaty reduces the rate.
Interest on certain bonds is taxed at 14 percent (15.4 percent with local tax) and certain foreign-currency bonds at 0 percent.PwC Worldwide Tax Summaries · checked 2026-10-19VAT is charged at a standard rate of 10 percent, with exports and certain goods or services zero-rated or exempt.
Chambers and Partners (Dentons Lee) · checked 2026-10-19Korea has implemented the OECD global minimum tax, with the Income Inclusion Rule applying to fiscal years beginning on or after 1 January 2024.
Large multinational groups; QDMTT safe-harbour status remains subject to OECD peer review.Chambers and Partners (Dentons Lee) · checked 2026-10-19The arm's-length principle applies to cross-border related-party transactions under the International Tax Coordination Law, with master file, local file and country-by-country reporting depending on group size.
Chambers and Partners (Dentons Lee) · checked 2026-10-19Exports and services supplied overseas are zero-rated for VAT.
Enterprise Singapore · checked 2026-10-19
Read the full guide: Tax, accounting and reporting
Scope
What the service covers here
- 01Review the proposed cross-border structure
- 02Identify direct and indirect tax exposures
- 03Consider withholding, treaty and transfer-pricing issues
- 04Coordinate implementation across the relevant jurisdictions
Key questions
What we will work through with you
- What needs to be decided before tax & international structuring work starts?
- Who is professionally responsible in each country?
- Which other work, such as tax or employment, must happen at the same time?
- What information and decisions are needed from the business?
If your work involves another country or another area of expertise, WONE Global brings in the right professional and keeps all advisers informed.
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Cases
What clients bring to Tax & International Structuring
The cases this service leads or joins, each with what is at stake, how WONE Global handles it and who handles it in South Korea.
Urgent We've received a tax notice from another country. Do we have to pay?Tax assessments, disputes & managementUrgent We sell online to customers abroad. Do we have to register for their VAT or GST?Tax assessments, disputes & managementUrgent Tax was deducted abroad and again at home. Can we get it back?Payments, FX, digital assets & treasuryUrgent The tax authority wants our transfer pricing documentation. We don't have any.International tax planning & transfer pricingWhat tax filings do we have to make in each country, and when?Tax assessments, disputes & managementHow should we price and invoice customers abroad so we actually get paid?Contracts, commercial disputes & collectionsAt what point do our sales abroad mean we need a local company?International tax planning & transfer pricingShould we reorganise how our regional business is run?International tax planning & transfer pricingCan we centralise finance, HR or IT in one country?International tax planning & transfer pricingHow do we move cash between our companies in different countries?Payments, FX, digital assets & treasury
WONE Global Intelligence
Ask about tax & international structuring in South Korea
Ask in your own words. Answers come from WONE Global's checked records, with every source shown, and end with the named Partner who can act. Go deeper on any point, or build a decision file.
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