법인세 파급효과 2026 — 최저한세 15%는 이익만 옮길까, 공장도 옮길까Corporate Tax Spillovers 2026: Will a 15% Minimum Move Profits or Factories?

The timing matters. Chapter 3, “Intangible Yet Real: Spillovers from Corporate Income Taxation,” is scheduled for October 5 at 9 a.m. US Eastern time, or 10 p.m. in Korea. At the research cutoff, shortly after 3 a.m. Korean time on October 5, the official page still said “Coming Soon.” Source: IMF — October 2026 WEO, Chapter 3 공개 일정

This is a preview analysis, not a summary of findings from the unreleased chapter. It draws on verified rules and earlier research, with implications for Korean businesses identified as conditional analysis. The useful distinction is between cash saved on tax, output created by a new facility, and revenue collected by a government.

Corporate tax spillovers: profits can move before factories

Imagine technology developed in Korea, used by an overseas factory, with products sold through a local sales company. Royalties—the payments for using that technology—affect where profits are reported. The location of taxable income can change even when the number of finished products sold does not. This is an illustrative business structure, not a claim about a particular company.

Patents, software and brands are intangible assets: valuable resources without a physical form. They can be used across several countries, and comparable market prices may be difficult to find. That does not make profit allocation arbitrary. Related companies must consider arm’s-length pricing—the terms independent businesses would use—and the applicable tax rules. Source: 국세청 — 추가세액계산 흐름도

Real production usually moves more slowly. A factory needs power, skilled workers, access to customers, equipment installation and permits. More reported profit in a low-tax country does not by itself demonstrate higher employment or productivity there. The IMF’s 2014 spillovers report treated the effects of one country’s tax system on others as a distinct policy issue. Source: IMF — Spillovers in International Corporate Taxation (2014)

Intangibles also affect how researchers measure investment responses. In a 2014 IMF working paper, Sophia Chen and Estelle Dauchy examined temporary US investment incentives in the early 2000s. Accounting for intangible assets generally produced larger estimated investment responses. This was the authors’ research on that historical sample, not an IMF policy position or a new estimate for Korean firms in 2026. Source: Chen·Dauchy — 무형자산과 투자 세제, IMF WP/14/104 (2014-06-12)

Why a 15% minimum still leaves room for tax competition

The global minimum tax imposes additional tax on low-taxed income of sufficiently large multinational groups. Korea’s National Tax Service describes a scope threshold of at least EUR 750 million in adjusted consolidated revenue in at least two of the four preceding fiscal years. Smaller exporters are not automatically covered, and excluded-entity rules also matter. Source: 국세청 — 글로벌최저한세 신고대상

The 15% figure does not require every country to adopt the same statutory corporate tax rate. The rules aggregate adjusted income and taxes for group entities in each jurisdiction to calculate an effective tax rate. If that rate falls below the minimum, a top-up tax calculation follows. Source: OECD — Global Minimum Tax: 세율·공제·과세 순서

The top-up tax base also excludes an amount linked to payroll and tangible assets. This substance-based income exclusion removes part of the income associated with real operations from the additional-tax base. It is therefore incorrect to assume that every business pays exactly 15% of its accounting profit. Source: OECD — Global Minimum Tax: 세율·공제·과세 순서 Source: 국세청 — 추가세액계산 흐름도

Consider an illustrative calculation in arbitrary monetary units. Adjusted income of 100 and adjusted taxes of 10 give a 10% effective rate. With no exclusion, the top-up is 5. If the exclusion is 10, the calculation is 5% multiplied by 90, giving 4.5. This example omits other adjustments, reliefs and allocation between governments. It is neither an IMF forecast nor an actual company’s tax bill. Source: 국세청 — 추가세액계산 흐름도

This does not make building a factory automatically profitable. Increasing the exclusion requires qualifying assets or payroll, which cost money. If financing, electricity and idle-capacity costs exceed the tax benefit, the incentive to invest weakens. This is an economic interpretation of the mechanism, not a measured result from the forthcoming chapter.

Who collects the tax—and how much of an incentive survives?

A tax concession in a low-tax country does not necessarily become an equal saving for the business. A qualified domestic minimum top-up tax, or QDMTT, gives the host jurisdiction first collection rights. The income inclusion rule, IIR, operates at parent-company level; the undertaxed profits rule, UTPR, can allocate remaining top-up tax to other implementing jurisdictions. Actual outcomes depend on implementation, qualification and relief conditions. Source: 국세청 — 추가세액계산 흐름도

1. 1
   Host jurisdiction

   First collection through QDMTT

2. 2
   Parent level

   Relevant amount under IIR

3. 3
   Other implementers

   UTPR for remaining amounts

That ordering complicates the implications for Korean tax revenue. If an overseas subsidiary’s host country collects first, less may remain to be allocated at the Korean parent level. Changes in the group’s total tax bill and changes in Korean public revenue are different questions. For inward foreign direct investment, announced amounts also need to be distinguished from equipment actually installed and workers actually hired.

The framework itself changed in 2026. The OECD’s January 5 Side-by-Side package included safe harbours for groups with ultimate parents in eligible jurisdictions and for certain substance-based tax incentives. A safe harbour grants specified relief when its conditions are met. These arrangements make it too simplistic to say that the minimum tax has eliminated every investment incentive. Source: OECD — Side-by-Side 합의 발표 (2026-01-05)

On September 11, the OECD released a legislative review framework, an updated information return and further administrative guidance. The return changes apply to specified fiscal years. Calling a benefit a “tax credit” is not enough to establish its cash value: eligibility, accounting treatment and additional taxation must be assessed together. Source: OECD — 최저한세 일관성·신고·행정지침 패키지 (2026-09-11)

Three channels for Korean chips, batteries and platforms

For semiconductors, after-tax returns and the date a factory can begin operating both matter. Consider a conditional scenario: if a competing country’s incentive survives as a cash benefit and power and labour are available, a new line may become more attractive there. Korean equipment and materials suppliers could gain orders, while stronger local sourcing could reduce the share exported directly from Korea.

Battery projects add another constraint: customer orders and capacity utilisation. A large tax benefit cannot spread fixed costs across units that are never sold. Conversely, a long-term supply agreement combined with reliable incentive payments could improve the cash flows lenders assess. This describes a decision framework, not verified expansion or earnings growth at any named company.

For platform and software businesses, the entity receiving royalties and the location of development staff need to be considered together. Reallocating royalty income can change taxable profits and after-tax earnings without creating more users or improving service productivity. If development teams also relocate, effects on wages, suppliers and local spending can become more substantial.

The path to household consumption differs accordingly. A change in reported profits alone may have little direct effect on household income. Domestic equipment orders and hiring can reach consumers through wages and supplier revenues. Governments granting incentives must also ask how much forgone revenue is recovered through genuinely additional activity.

Tax treaties are another layer. They allocate taxing rights and help reduce double taxation, so royalty withholding—the tax deducted when a payment is made—and dispute resolution also require attention. Checking the minimum-tax rules does not replace checking the relevant treaty and its anti-abuse provisions. No treaty rate for a particular country pair is assumed here. Source: OECD — Tax treaties

Cheaper tax, costlier money: what the IMF, OECD and US Treasury said

In her October 1 briefing, IMF Communications Director Julie Kozack discussed energy prices, monetary-policy expectations, high debt and term premia as drivers of rising bond yields. A term premium is the extra compensation investors demand for committing funds for longer. For businesses, a smaller tax bill can be offset by more expensive financing. We traced how higher yields feed into Korean companies’ interest costs in the US 10-year Treasury yield warning. Source: IMF — Julie Kozack 브리핑, 2026-10-01

On January 5, OECD Secretary-General Mathias Cormann said the agreement improved tax certainty, reduced complexity and protected tax bases. The same day, US Treasury Secretary Scott Bessent emphasised US taxing sovereignty over US-headquartered groups and protection for research and investment incentives. Together, the statements show shared-rule stability operating alongside national industrial-policy priorities. Source: OECD — Side-by-Side 합의 발표 (2026-01-05) Source: 미 재무부 — Scott Bessent 최저한세 합의 성명 (2026-01-05)

Bessent’s statement should not be applied mechanically to Korean businesses. Having a factory in the United States is different from having a US ultimate parent. A US subsidiary of a Korean-headed group does not automatically obtain the same relief; the group structure and specific conditions matter. Source: 미 재무부 — Scott Bessent 최저한세 합의 성명 (2026-01-05) Source: OECD — Side-by-Side 합의 발표 (2026-01-05)

Risk appetite is also uneven. In the supplied snapshot, CNN’s US Fear & Greed reading was 31.2, or Fear, on October 2, down 5.8 points from 36.9 a week earlier and 14.9 points from 46.1 a month earlier. GoldKimp’s KOSPI reading was 60.5, or Greed, on October 1. Different methods and dates prevent treating their numerical gap as directly comparable. Matching Korean weekly and monthly history was unavailable, so no Korean trend is inferred. Source: CNN — Fear & Greed (제공 스냅샷 2026-10-02) Source: GoldKimp — KOSPI Fear & Greed (제공 스냅샷 2026-10-01)

SentimenTrader’s Smart Money and Dumb Money confidence indicators summarise different types of investor behaviour. Its homepage did not display current values or a latest-update date during this check. The public September 25 summary said their spread returned above zero on September 16. That is a dated observation, not today’s individual readings or a measure of institutional net purchases. Source: SentimenTrader — Smart/Dumb Money 공개 대시보드 확인 Source: SentimenTrader — 2026-09-25 공개 주간 요약

There is no evidence here that tax news caused these sentiment readings. Weaker US risk appetite nevertheless makes current cash and financing terms relevant when assessing distant tax benefits. Our earlier discussion of World Bank private-capital mobilisation likewise distinguished headline guarantees from financial close and project conditions. Tax support needs the same attention to cash retained after contractual conditions and additional taxation.

Three questions to take to the IMF chapter

First, examine how the chapter distinguishes profit allocation from real investment. Foreign direct investment can include acquisitions and financial transactions. An increase in its headline amount needs to be connected to new facilities, production and employment before translating it into Korean supplier orders.

Second, check whether intangible-intensive firms are estimated separately and whether results come from observed post-reform data or modelled scenarios. Third, examine assumptions about other governments’ responses and the 2026 minimum-tax changes. If another country changes its own tax or support policy, the initially calculated revenue and output effects can change.

When reading Korean company results, combine overseas tax exposure with cash taxes paid, capital expenditure actually executed and capacity utilisation. A one-off tax effect can lift net profit without a matching improvement in operating cash generation. Equity-market implications depend on the size of the after-tax cash-flow improvement and how much investors have already priced in.

Tax competition may place more weight on facilities and employment alongside profit allocation. That transition is not automatic, and the available evidence does not establish Korea as an unambiguous winner. A macroeconomic benefit requires incentives to induce additional investment that meets customer demand and raises production and wages.

Sources and references

• IMF — Julie Kozack 브리핑, 2026-10-01
• IMF — October 2026 WEO, Chapter 3 공개 일정
• IMF — Spillovers in International Corporate Taxation (2014)
• Chen·Dauchy — 무형자산과 투자 세제, IMF WP/14/104 (2014-06-12)
• OECD — Global Minimum Tax: 세율·공제·과세 순서
• OECD — Side-by-Side 합의 발표 (2026-01-05)
• OECD — 최저한세 일관성·신고·행정지침 패키지 (2026-09-11)
• 미 재무부 — Scott Bessent 최저한세 합의 성명 (2026-01-05)
• OECD — Tax treaties
• 국세청 — 글로벌최저한세 신고대상
• 국세청 — 추가세액계산 흐름도
• CNN — Fear & Greed (제공 스냅샷 2026-10-02)
• GoldKimp — KOSPI Fear & Greed (제공 스냅샷 2026-10-01)
• SentimenTrader — Smart/Dumb Money 공개 대시보드 확인
• SentimenTrader — 2026-09-25 공개 주간 요약