ESPP
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Taxation of Employee - ESPP

Tax on discount at purchase.

Tax on sale, subject to an exclusion.

Sub Deduction - ESPP

Yes, if reimbursement made by subsidiary to the parent and certain other conditions satisfied.

Exchange control restrictions may impact ability to implement reimbursement arrangement.

Please contact Baker McKenzie for more information.

Withholding and Reporting

Income Tax:

Generally, no withholding provided subsidiary does not reimburse parent. Effective 1 January 2024, employer is required to report option income on an annual basis.

Social Insurance Contributions:

Yes, employee and employer social insurance contributions apply. Employer technically required to withhold employee contributions.

Securities Restrictions - ESPP

Generally, no, as employee exemption should apply.

Korean residents previously could not sell foreign-listed shares through foreign brokers or deposit proceeds abroad, requiring engagement with Korean domestic brokers. However, a recent legislative action promulgated on 5 March 2024 now allows Korean resident employees of multinational companies to dispose of overseas-listed securities without using Korean licensed brokers.

Exchange Controls - ESPP

Remittance of funds to purchase shares must be "confirmed" by a Korean foreign exchange bank if funds wired abroad. If intercompany offset used to effect purchase of shares, the local entity must report the intercompany offset to the foreign exchange bank at the time of offset.

Employees may be required to report deposit of proceeds with a value in excess of USD 5,000 into a non-Korean bank account.

Please contact Baker McKenzie for details.

Plan Entitlement - ESPP

Written disclaimer should be included in grant documents to reduce risk of entitlement. Equity income likely will constitute "wages", particularly if there is reimbursement.

Co-mingling of payroll deductions with general corporate funds is not permitted, so a separate bank account is recommended.

Data Privacy - ESPP

Personal Information Protection Act in effect.

Written consent from employees for the collection, use and transfer of data abroad is required and specific data and recipients must be named.