This issue highlights certain tax amendments that were passed by the National Assembly of Korea to be effective as of January 1, 2021. The amendments include a number of provisions that advocate the taxpayer’s right such as change in the base date for interest on refund request or tax audit notice procedure. For ease of reference, we include a link for Korean version in case you would like to read it in Korean or forward it to your Korean colleagues.


1. Denial of interest expense on hybrid financing (ITCA Article 25)

2. Extension of roll-back period of advanced pricing agreements (APA) (ITCA Article 14 (3))

3. Change of due dates for certain informational filings (ITCA Article 16)

4. Obligation to file statements of payments on Korean sourced income of foreign corporations and non-residents (CITA Article 120-2)

5. Mutual Agreement Procedure (MAP) (ITCA Article 42, 46, 47)

6. Introduction of arbitration under tax treaties (ITCA Article 43)

7. Change of the base date from which interest accrues on refund request (PED of NTBA Article 43-3 (1)(3), (5))

8. Notice of tax audit and notice of tax audit result (PED of NTBA Article 63-6, 63-13)

9. Place of supply for electronic services (VAT Act Article 20)

10. Carryforward periods for tax credits and net operating losses (CITA Article 13, 76-13, IITA Article 45, STTCA 144)

11. 45% marginal tax rate for resident individuals (IITA Article 55)

12. Financial Investment Income (FII) (IITA Article 87-2 and Article 87-27)

13. Reduction in securities transaction tax (STT) (STTA Article 8)

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