"36 Pages of Reports, Thousands of Documents to Verify"... Exhausted Before Writing [‘Countdown’ Global Minimum Tax]⑤

Introduction of Global Minimum Tax Creates Information Report Form
To Be Used from First Filing and Payment in June 2026
Two-Thirds of Instructions Explain How to Fill Out
"Hundreds of Documents Needed to Fill a Single Blank"

The first page of the Global Minimum Tax Information Report. The first page requires entering the basic information of the multinational enterprise group to be reported. Photo by Kim Hyung-min

With the introduction of the global minimum tax (Pillar 2) this year, new related documents have also been created. The ‘Global Minimum Tax Information Report’ is one of them. The report form was officially established on the 22nd of last month and is expected to be used by companies when filing in June 2026. Companies identified as subject to the global minimum tax must fill out corporate information on this report form and submit it to the relevant tax office for filing.

Although there are still two years left until the actual filing, companies are already struggling with this report. Not only is it over 30 pages long, but the form itself is complex, and the preparation process required to complete the report is not easy.

According to tax authorities and corporate officials on the 27th, the National Tax Service has recently been flooded with inquiries and complaints from companies about how to fill out the report. A common complaint among companies is that "to fill in a single blank, hundreds of pages of documents need to be collected and verified." This is especially true for large corporations with many overseas subsidiaries. Kim Moon-hee, head of the New International Tax Response Division at the National Tax Service, said in a phone interview, "Companies need to secure accounting and tax data processed by each subsidiary according to the global minimum tax standards, and then calculate the effective tax rate by country using the secured data, which makes it somewhat difficult for companies. While companies do have an obligation to collect data, some subsidiary countries do not follow international standards in their tax laws, so the circumstances vary greatly, and we understand the companies’ concerns."

Global Minimum Tax Information Report, Page Two. From the second page onward, the detailed report content must be entered. First, the form is structured to report the subsidiary information of the reporting company and the details of its governance structure. Photo by Kim Hyung-min

Global Minimum Tax Information Report, Third Page. The third page explains how to fill out the second page mentioned earlier. The instructions are fundamentally lengthy and complex. A total of 21 pages out of the 36-page report are dedicated solely to the instructions. Photo by Kim Hyungmin

The complexity of the report form is due to its design to align with the purpose of the global minimum tax, which aims to prevent illegal tax avoidance by multinational corporations. Countries that have agreed to introduce the global minimum tax, including OECD member countries, require companies to report detailed information on governance and income in the report form. The report form introduced in Korea is simply a translated version of the OECD’s standardized template. Since it is an internationally agreed-upon form, the Korean government ministries cannot arbitrarily modify it to fit domestic circumstances.

The 36-page report requires basic information such as the name, address, and representative of the parent company that may bear additional tax liabilities, as well as listing all subsidiaries, including their fiscal years, income, and country of residence. Notably, the instructions for completing the form alone cover about two-thirds of the document, totaling 21 pages.

The criteria for accepting the reported content are also ambiguous. For example, in the section for ‘Multinational Enterprise Group General Accounting Information,’ companies must submit the consolidated financial statements, accounting standards, and currency (ISO code) of the ultimate parent company, with instructions stating that "a reasonable level of good faith effort must be made." In other words, this is an item that must be completed ‘diligently and meticulously,’ but companies find it difficult to gauge exactly how much ‘diligence’ is required.

The National Tax Service is currently reviewing the possibility of creating a system that allows companies to file and pay electronically, like other taxes, to alleviate these difficulties. Kim Moon-hee said, "While major changes to the report form are unlikely, ongoing domestic and international discussions mean that the OECD may revise the guidelines and address inquiries to move in a more reasonable direction."