Provisions | AITA |
Article 61 [Definition] | |
Article 62 [Scope of Applications] Article 63 [Taxpayer] Article 64 [Location of Enterprises], and Article 65 [Location of Tax payment of Enterprises] | Excluded entities: (i) government entities, international organizations, non-profit organizations, and pension funds, (ii) investment funds and real estate investment vehicles but only when they are the UPE of an MNE Group, and (iii) entities directly or indirectly owned by (i) or (ii).
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Article 66 [Calculation of Globe income or loss] | The amount of GloBE income or loss of a Constituent Entity is determined by taking the financial accounting net income or loss for the Constituent Entity for the fiscal year adjusted by certain items (e.g., net tax expense, dividends) prescribed in the Enforcement Decree.
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Article 67 [Computation of Adjusted Covered Taxes] | |
Article 68 [Post-filing adjustments and Tax Rate Changes] | |
Article 69 [Computation of ETR] | |
Article 70 and Article 71 [Computation of Top-Up Tax] | |
Article 72 [Application of the IIR] | |
Article 73 [Application of the UTPR] | 50% x (total number of employees of each Constituent entity of the corresponding MNE Group / the total number of employees of corresponding Constituent Entities of the MNE group that has a qualified UTPR in force), plus 50% x (sum of the net book values of tangible assets of corresponding Constituent Entities of the MNE group/ the sum of the net book values of tangible assets of corresponding Constituent Entities of the MNE Group that has a qualified UTPR in force)
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Article 74 [De minimis exclusion] | |
Article 75 and Article 77 [Special rules for Minority-owned constituent entities and Joint Ventures] | |
Article 76 (Special rules for restructuring) | However, if the transfer is part of a qualified global reorganization, the transfer is effectively disregarded, with the disposing entity disregarding any gain or loss, and the acquiring entity adopting the carrying values from the disposing entity.
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Article 81 [Special rule for the first year of application] | |
Article 83 [The GloBE Information Return] | A Domestic Constituent Entity must file a GloBE Information Return with the Korean tax authorities no later than 15 months (18 months in the case of the first year of application) after the last day of the reporting fiscal year. This obligation, however, will be exempt when Overseas Constituent Entities file the GloBE Information Return with another jurisdiction.
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Article 84 [Report and payment of allocated additional Top-Up Taxes] | |