Korea Global Minimum Tax (Pillar 2) Top-up Tax Calculator
Estimate the Pillar 2 top-up tax for one jurisdiction of a multinational group under Korea's global minimum tax (글로벌 최저한세). Enter the jurisdiction's net GloBE income, adjusted covered taxes and substance-based income exclusion; the calculator works out the effective tax rate, the top-up percentage against the 15% minimum and the top-up tax. Korea's income inclusion rule has applied to fiscal years beginning on or after 1 January 2024, the undertaxed profits rule from 2025 and a domestic minimum top-up tax from 1 January 2026.
Korea's global minimum tax (글로벌 최저한세) applies the OECD Pillar 2 rules: a multinational group with consolidated revenue of EUR 750 million or more must pay at least 15% tax on its profit in every jurisdiction where it operates. Where the effective tax rate in a jurisdiction is below 15%, a top-up tax brings it up to the minimum.
How the Korea global minimum tax top-up is calculated
| Step | Formula | Example |
|---|---|---|
| 1. Scope | Group revenue of EUR 750M or more in at least 2 of the 4 fiscal years before the tested year | 4 of 4 years: in scope |
| 2. Effective tax rate | Adjusted covered taxes ÷ net GloBE income, per jurisdiction | 15 ÷ 150 = 10% |
| 3. Top-up tax percentage | 15% − effective tax rate | 5% |
| 4. Excess profit | Net GloBE income − substance-based income exclusion | 150 − 20 = 130 |
| 5. Top-up tax | Top-up percentage × excess profit, less qualified domestic top-up tax | 5% × 130 = EUR 6.5M |
The worked example is the calculator's default: EUR 150 million of GloBE income with EUR 15 million of covered taxes is a 10% effective rate, 5 points short of the minimum. After a EUR 20 million substance-based income exclusion, excess profit is EUR 130 million and the top-up tax is EUR 6.5 million. A jurisdiction taxed at 18% produces no top-up.
When each rule applies in Korea
Korea legislated the global minimum tax in three steps. The income inclusion rule (IIR), under which a Korean parent pays the top-up for low-taxed foreign entities, applies to fiscal years beginning on or after 1 January 2024. The undertaxed profits rule (UTPR), a backstop, applies to fiscal years beginning on or after 1 January 2025. A domestic minimum top-up tax, which lets Korea collect the top-up on low-taxed Korean profits itself, is effective from 1 January 2026. These dates were unchanged when this page was last checked, so 2027 fiscal years fall under all three.
What the substance-based income exclusion is
The exclusion removes a routine return on real activity from the top-up base. Under the OECD model rules it is based on payroll costs and the carrying value of eligible tangible assets in the jurisdiction. Because it depends on your own payroll and asset figures and on the percentages in force for the fiscal year, the calculator asks for the exclusion as an amount rather than building in a rate.
Limits of this estimate
Real GloBE calculations start from financial-accounting income and apply many adjustments, deferred-tax rules and elections. This tool is for a first look at exposure in one jurisdiction; it is not a filing calculation.
Sources: PwC Worldwide Tax Summaries, Republic of Korea, corporate taxes on income (reviewed 4 June 2026) for the Korean effective dates and revenue test; EY summary of the OECD Pillar Two model rules for the calculation steps. Last updated: October 2026.