Extension of statutory taxation period for offshore transaction : Article 26-2, Framework Act on National Taxes (국세 부과의 제척기간의 연장)

Korean tax authorities are getting more interested in international/offshore transactions. In Korea, there are many regulations in relation to residents’ overseas assets and any kind of international transactions which might trigger tax issues in Korea.

Effective Jan 1, 2019, statutory taxation period (국세 부과의 제척기간) for international/offshore translation is increased as below.

  • Case 1. Fraud and other unlawful activities : 15 years
  • Case 2. Failure to file taxes : 10 years (previously 7 years)
  • Case 3. Under-filing of taxes : 7 years (previously 5 years)


For more information, please contact Song I Yoon –  [email protected]


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