Korea Oligopolistic Shareholder Deemed Acquisition Tax Calculator

Estimate Korea's deemed acquisition tax when a shareholder and prescribed related persons acquire shares in an unlisted corporation, substantively exercise shareholder rights, and their combined voting interest strictly exceeds 50% (Framework Act on Local Taxes Article 46(2); Local Tax Act Article 7(5)). A first-time oligopolistic shareholder is taxed on the full post-transaction ratio; an existing or returning shareholder is taxed only on the increase above the previous high ratio under Enforcement Decree Article 11, with no arbitrary five-year lookback. The calculator applies the deemed ratio to covered assets at book value, separates the 2%, 6%, and 10% acquisition-tax classes, estimates the 10% special rural tax where applicable, and notes the 60-day filing deadline.

Tax scenario inputs

Enter Korea-related tax assumptions in KRW. The model uses a simplified effective-rate estimate.

Taxable property base

₩5,000,000,000

Estimated property tax

₩3,000,000,000

Total with surtax or credit

₩3,000,000,000

Monthly reserve target

₩250,000,000

This English page is a simplified Korea-related tax planning estimate. It does not reproduce official forms, progressive brackets, exemptions, local surtaxes, filing classifications, or eligibility decisions. Confirm current Korean rules before filing, paying, investing, or restructuring.

Related calculators

Korea-specific 2026 local-tax estimate

This calculator applies Korean law as verified on July 23, 2026.
It is intended for a share acquisition in a Korean non-listed corporation and does not replace a local tax return, a ruling by the competent local government, or professional advice.
All amounts are in KRW and all share percentages aggregate the shareholder and the special related persons counted under Korean local-tax rules.

What is deemed acquisition tax for an oligopolistic shareholder?

Korea can treat a shareholder as having acquired the taxable assets owned by a corporation even though the legal transaction transferred shares rather than the assets themselves.
Local Tax Act Article 7(5) applies when a person acquires shares or an equity interest and becomes an oligopolistic shareholder under Framework Act on Local Taxes Article 46(2), subject to the narrower related-party scope in the Enforcement Decree of the Local Tax Act.

The calculation is not the share purchase price multiplied by 2.2%.
The base starts with the corporation’s book value of acquisition-taxable assets, multiplies it by the legally taxable share ratio, applies 2%, 6%, or 10% acquisition-tax rates by asset class, and then adds special rural development tax where applicable.

The three conditions that create oligopolistic-shareholder status

More than 50%

The aggregate voting interest must strictly exceed 50%.
Exactly 50% does not meet the threshold, and non-voting shares are excluded from the numerator and denominator under Article 46.

Related-person aggregation

The test combines the principal shareholder with qualifying relatives, economically connected persons, and certain directly controlled entities.
The detailed scope comes from Enforcement Decree Article 10-2 and Framework Act Enforcement Decree Article 2.

Substantive exercise of rights

A name on the shareholder register is not always enough.
Voting, disposal, and other shareholder rights must enable substantive control of the corporation; a security-only or temporary holding can require a different conclusion.

Two statutory exclusions

  • A corporation listed on a qualifying securities market is excluded from Article 46
  • Shares or interests issued and acquired at the corporation’s formation are excluded by Local Tax Act Article 7(5)

How the taxable share ratio changes by ownership history

Enforcement Decree of the Local Tax Act Article 11 distinguishes a first-time oligopolistic shareholder from an existing or returning one.
This distinction can turn the same share purchase into a much larger or smaller deemed acquisition.

Taxable share ratio under Korean oligopolistic-shareholder rules
Ownership historyExampleTaxable ratio
First time above 50%40% before, 60% afterFull post-transaction 60%
Already oligopolistic60% before, 70% after, prior high 60%Increase of 10%
Returns after falling to 50% or below40% before, 65% after, prior high 60%Excess of 5%
Returns below prior high40% before, 55% after, prior high 60%0%

No arbitrary five-year lookback

The current Article 11 uses the previous highest ownership ratio and does not impose a five-year cutoff.
Enter the highest qualifying aggregate ratio from the relevant full ownership history rather than a five-year maximum borrowed from another rule or an outdated summary.

Book-value tax base and covered assets

Local Tax Act Article 10-6(4) measures the deemed acquisition from the total value of the corporation’s covered assets shown in its financial statements and other books.
In ratio form, each asset-class base equals its book value at the deemed acquisition date multiplied by the taxable share ratio.

Article 7(1) covers real estate, vehicles, machinery, aircraft, vessels, standing timber, mining rights, fishing rights, aquaculture rights, and specified golf, equestrian, condominium, sports-facility, and yacht memberships.
Trust property registered in the trustee’s name can also be included under Article 7(5).
The share price, enterprise value, net assets after liabilities, and goodwill are not substitutes for this statutory asset schedule.

Korean deemed acquisition tax rates by corporate asset class
Asset classStatutory contextAcquisition taxIf rural tax fully applies
Standard assetsLocal Tax Act Article 15(2)(3)2%2.2%
Specified metro-area assetsArticle 13(1) head-office or factory cases6%6.6%
Luxury assetsArticle 13(5) golf course, luxury home, entertainment venue, or vessel10%11%

Calculation sequence

  1. Determine whether the corporation is non-listed, the post-transaction aggregate voting interest exceeds 50%, and the group can substantively exercise shareholder rights.
  2. Exclude shares issued and acquired at formation, then classify the ownership history as first-time, existing, or returning.
  3. Compute the taxable ratio as the full post-transaction ratio for a first-time case or the excess over the previous high for an existing or returning case.
  4. Multiply each covered asset book value by that ratio and apply the 2%, 6%, or 10% acquisition-tax rate.
  5. Apply the 10% special rural development tax to the acquisition-tax amount that is not exempt under the Act on Special Rural Development Tax.
  6. Add no local education tax because Local Tax Act Article 151(1)(1) expressly excludes Article 15(2) acquisitions.

Worked examples

First-time move from 40% to 60%

Assume KRW 5 billion of standard covered assets and no prior oligopolistic-shareholder history.
The taxable ratio is the full 60%, so the deemed base is KRW 3 billion.
Acquisition tax is KRW 60 million, special rural development tax is KRW 6 million, and the total is KRW 66 million.

Existing move from 60% to 70%

With the same KRW 5 billion of standard assets and a previous high of 60%, only the 10% excess is taxable.
The deemed base is KRW 500 million, acquisition tax is KRW 10 million, rural tax is KRW 1 million, and the total is KRW 11 million.

Mixed-rate first-time case

Assume a 60% taxable ratio, KRW 2 billion of standard assets, KRW 1 billion of Article 13(1) assets, KRW 500 million of luxury assets, and KRW 200 million of rural-tax-exempt standard assets.
Acquisition tax is KRW 24 million plus KRW 36 million plus KRW 30 million, or KRW 90 million.
The rural-tax base tax is KRW 87.6 million, so rural tax is KRW 8.76 million and the combined estimate is KRW 98.76 million.

Practical checks before relying on the result

Confirm the related-person perimeter

Do not enter only the buyer’s direct percentage.
Reconcile family relationships, employees, economically connected persons, and directly controlled entities under the specific local-tax definitions.
A transfer inside the same related group may create no aggregate increase even though one member acquires shares.

Reconcile the fixed-asset ledger

Review the financial statements, fixed-asset register, depreciation schedule, trust-property data, asset locations, and membership rights as of the deemed acquisition date.
A company with no real estate can still own vehicles, machinery, vessels, rights, or memberships within Article 7(1).

File by asset jurisdiction

Local Tax Act Article 20(1) generally requires filing and payment within 60 days from the deemed acquisition date.
Assets in multiple cities, counties, or districts can involve more than one competent local government, and holiday extensions or local forms should be confirmed separately.

Limits of this estimator

  • It accepts the related-group percentage as an input and does not decide a disputed related-person relationship
  • It does not determine contested substantive control, which depends on contracts and actual voting or disposal rights
  • It does not classify an asset as an Article 13(1) or Article 13(5) heavy-rate asset for the user
  • It excludes Local Tax Special Treatment Restriction Act reductions, ordinance rate adjustments, penalties, and amended returns
  • It treats the entered rural-tax-exempt standard asset amount as exempt only from special rural development tax

Frequently asked questions

Does a first-time move from 49% to 51% tax only the 2% increase?

No.
If the group has no prior oligopolistic-shareholder history, Article 11 treats all shares held when it first crosses the threshold as acquired, so the taxable ratio is 51%.

Is the combined rate always 2.2%?

No.
The 2.2% shorthand assumes a 2% standard acquisition-tax rate and special rural development tax equal to 10% of that full acquisition-tax amount.
Rural-tax exemptions can reduce it, while Article 13 assets can raise acquisition tax to 6% or 10%.

Is there a five-year reset for the previous high ratio?

The current Article 11 contains no five-year limit.
A returning group should compare the post-transaction ratio with the relevant previous oligopolistic-shareholder high across the full history.

Why is local education tax zero?

Local Tax Act Article 151(1)(1) excludes acquisitions governed by Article 15(2).
Oligopolistic-shareholder deemed acquisition is listed in Article 15(2)(3), so this estimator adds no local education tax.

Official sources and rule date

The Korean body and this English guide reuse the same primary-source review completed through the National Law Information Center OPEN API on July 23, 2026.
The reviewed current versions were Local Tax Act MST 282559, its Enforcement Decree MST 287223, Framework Act on Local Taxes MST 283257, its Enforcement Decree MST 286471, and Act on Special Rural Development Tax MST 285905.

  • Local Tax Act Articles 7(5), 10-6(4), 13, 15(2)(3), 20(1), and 151(1)(1)
  • Enforcement Decree of the Local Tax Act Articles 10-2 and 11
  • Framework Act on Local Taxes Article 46(2) and its Enforcement Decree Article 2
  • Act on Special Rural Development Tax Articles 3, 4, and 5
  • Supreme Court cases 2015Du3591 and 2024Du42116 on substantive shareholder-right exercise

Estimate the tax before signing the share deal

Gather the related-group voting percentages, the full previous ownership high, and the corporation’s covered-asset ledger before calculating.
Then confirm the 60-day filing deadline, asset classification, exemptions, and competent local governments with a Korean local-tax professional.