2. Place of Tax Payment

a. General

(1) Domestic corporation

Domestic corporations shall pay corporation taxes at the place where head or main

office of the corporation is located.

(2) Foreign corporation

Foreign corporations with permanent establishments (PEs) in Korea shall pay

corporate taxes at the location of the PE. If a foreign corporation without a PE in Korea

earns income from real estate transactions, transfer of land or buildings, lumbering,

or transfer of timber, it shall pay the taxes at the respective place where such assets

are located. If a foreign corporation maintains two or more PEs in Korea, the place of

tax payment shall be the location of its main PE. In such a case, the main PE is the

PE earning the largest portion of business revenue at the year when the place of tax

payment is initially filed.

b. Designation of Place of Tax Payment

Notwithstanding the aforementioned provision, the government may designate a different

place of tax payment when the registered place of tax payment is determined to be

inappropriate. Such a designation may take place in the following cases.

(1) When the physical location of the head or main office of the corporation is different

from its registered address

(2) When a tax evasion is suspected based on the fact that the location of the head or

main office is not where the corporation's main assets are held or its business is

conducted

(3) When a foreign corporation has two or more PEs, and when the place of the main PE

is not clearly identifiable or established

(4) When a foreign corporation without a PE in Korea accrues income from real estate

(and other similar) transactions, sale or transfer of business assets, or business

transactions involving timber, but does not file its place of tax payment

c. Reporting Change of the Place of Tax Payment

When there is a change in the place of tax payment, the corporation must report it to the

tax office within 15 days from the date of change.

d. Withholding Taxes

The place of payment of taxes withheld by a domestic or foreign corporation shall be

where the head or main office of the domestic corporation (the main PE in case of a

foreign corporation) is located. However, if the securities issued by a domestic

corporation are transacted between non-residents or foreign corporations outside

Korea and capital gains arise from the transaction, the place for payment of the taxes

withheld shall be the location of the head or main office of the corporation that issued the

securities, notwithstanding the location of the tax withholding agent. Generally, the agent

withholding taxes will be the security company when the securities are transacted

through the company. In other cases, the seller of the securities may be the withholding

agent.