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Unraveling the "Korea Discount": A Comprehensive Analysis of South Korea's Equity Market Underperformance and Strategic Recommendations Executive Summary The "Korea Discount" is a persistent phenomenon where South Korean-listed companies trade at a consistent undervaluation compared to their global counterparts, even when their fundamental financial metrics, such as earnings per share (EPS) and book value per share (BPS), are comparable.1 This market anomaly is empirically evidenced by significantly lower Price-to-Book (PBR) and Price-to-Earnings (P/E) ratios. For instance, between 2014 and 2023, the PBR of Korean companies was a mere 58% of the average of advanced countries' indices and 34% of emerging markets' average, underscoring the severity of this valuation gap.1 While geopolitical risks are frequently cited as a contributing factor, a deeper analysis suggests they are not the primary driver. Taiwan, often considered similarly vulnerable militarily, does not experience a comparable market discount, which indicates that other, more fundamental issues are at play.1 Empirical research points to core problems stemming from historically weak corporate governance practices, inefficient capital allocation strategies by management, and, critically, low shareholder return policies.1 A stark illustration of this is South Korea's dividend payout ratio, which stood at a mere 19% in 2021, significantly trailing major global economies such as Taiwan (55%), the UK (48%), Germany (41%), France (39%), the US (37%), and even China (35%).1 The user's initial premise regarding the impact of high dividend taxes on the Korean stock market's weakness holds considerable validity. South Korea's integrated tax rate on corporate profits distributed as dividends is exceptionally high, reaching 59.2%. This figure far exceeds the OECD average of 36.8% and is notably higher than rates in major economies like the United States (46.9%) and Japan (44%).4 This substantial tax burden, combined with a capital gains tax structure that historically applied only to a small segment of "top shareholders," effectively incentivizes capital appreciation over dividend income for the vast majority of retail investors.5 This tax asymmetry discourages companies from distributing profits and investors from seeking dividend-paying stocks. Recognizing these systemic challenges, the South Korean government is actively pursuing reforms. Initiatives such as the "Corporate Value-Up Programme" and recent revisions to the Commercial Act are designed to enhance corporate governance and encourage higher shareholder returns.6 Furthermore, proposed tax reforms aim to mitigate the high individual dividend tax burden by introducing a separate taxation system for dividend income from companies with high payout ratios.8 To fully address the "Korea Discount" and foster a more robust equity market, key recommendations include: further strengthening corporate governance through rigorous enforcement and clear judicial interpretation of new regulations; optimizing tax policies to genuinely incentivize dividend payouts and attract both domestic and foreign investment; and implementing broader market development strategies that address underlying structural issues, such as the burden of excessive inheritance taxation.

1. The "Korea Discount": Definition and Core Drivers The persistent undervaluation of South Korean equities, widely known as the "Korea Discount," is a defining characteristic of the nation's financial landscape. This phenomenon signifies that Korean companies consistently trade at lower valuations than their international peers, even when their financial performance indicators are comparable.1 Understanding the empirical evidence and the underlying drivers of this discount is crucial for investors and policymakers alike. 1.1 Empirical Evidence of the "Korea Discount" The "Korea Discount" is not merely a perception but is quantitatively supported by key valuation metrics. A direct comparison of Price-to-Book (PBR) and Price-to-Earnings (P/E) ratios reveals a significant and sustained undervaluation of South Korean companies. Between 2014 and 2023, the PBR of Korean companies averaged a mere 58% of the average PBR of advanced countries' indices and only 34% of the average for emerging markets.1 At the close of 2023, the MSCI Korea Index traded at a PBR of 1.1 times, a stark contrast to the MSCI Taiwan Index at 2.4 times and the MSCI Japan Index at 1.4 times.1 The Korea Composite Stock Price Index (KOSPI) itself has been observed trading at a PBR of approximately 0.78 times, near a 20-year low, further illustrating the severity of this valuation gap.3 Similarly, the P/E ratio demonstrates this undervaluation. Over the same 2014-2023 period, the MSCI Korea Index's average P/E ratio was 12.2, which represented a 19% discount compared to Taiwan and a 28% discount relative to Japan.1 These consistent and significant PBR and P/E discounts, particularly when juxtaposed with regional competitors, indicate that the "Korea Discount" is not a transient market fluctuation but a deep-seated structural issue. This persistent undervaluation directly impacts investor confidence and influences capital allocation decisions, making Korean equities less attractive despite their underlying earnings potential. 1.2 Debunking Geopolitical Risk as the Primary Cause A common, yet often overstated, explanation for the "Korea Discount" is geopolitical risk, primarily stemming from tensions with North Korea. While such risks exist, empirical analysis suggests they are not the predominant factor driving the persistent undervaluation of South Korean equities. South Korea possesses substantial military strength, ranking fifth globally, and maintains a crucial alliance with the United States, which holds the top military ranking.1 If geopolitical risk were the primary determinant, one would expect other militarily vulnerable nations to exhibit similar market discounts. However, Taiwan, which faces its own significant geopolitical complexities, does not experience a comparable market undervaluation.1 This comparative observation suggests that the "Korea Discount" is rooted in more fundamental, internal economic and corporate structural issues rather than external security concerns. The continued focus on geopolitical factors as the main cause may distract from addressing the deeper, systemic challenges within the South Korean market. 1.3 Corporate Governance Deficiencies and Chaebol Influence A significant contributor to the "Korea Discount" lies in the historical and ongoing corporate governance deficiencies prevalent within South Korea's large, family-controlled conglomerates, known as "Chaebols." These structures have often prioritized the interests of controlling shareholders over those of minority investors. Chaebols, such as Samsung, LG, and Hyundai, are predominantly managed by founding families across generations.1 Their corporate structures often involve complex circular holdings and pyramid-like arrangements, which enable controlling families to exert significant influence over a vast network of public companies despite holding relatively low personal stakes.3 Historically, this control has facilitated practices detrimental to minority shareholders, including the siphoning of company assets through related-party transactions or unfair mergers.3 Numerous Chaebol family heads have faced legal challenges related to succession issues, highlighting the systemic nature of these governance concerns.1 These conglomerates played a pivotal role in South Korea's rapid industrialization, often benefiting from close ties with the government and receiving special favors, including guaranteed loans.11 This led to a monopolistic concentration of capital and economic activities, and in some cases, over-leveraging and diversification into unrelated sectors, contributing to past financial crises, such as the collapse of the Daewoo Group in 1999, which carried $80 billion in unpaid debt.10 The impact on minority shareholders has been profound, characterized by low dividend payouts as controlling families prefer to retain cash within the company to maintain control rather than maximize shareholder value.1 This approach limits the direct returns to investors and diminishes the overall attractiveness of South Korean equities. While research indicates that the discount applied to Chaebol firms has been significantly lower compared to other Korean companies since 2007, suggesting some evolution in governance practices, challenges persist.1 Despite ongoing reforms, controlling shareholders may still resist substantive changes in capital management, often preferring to offer only superficial adherence to minority shareholder demands and government desires.6 1.4 Low Shareholder Returns and Inefficient Capital Allocation Beyond corporate governance issues, the "Korea Discount" is also a direct consequence of South Korean companies' historically low shareholder return policies and their often inefficient capital allocation strategies. South Korea's dividend payout ratio in 2021 was notably low at 19%, significantly trailing major global economies.1 This low payout ratio means that a smaller proportion of corporate profits is distributed to shareholders compared to other developed and even emerging markets. This is compounded by the tendency of many South Korean companies to accumulate large cash reserves and hold idle assets, which contributes to a lower Return on Equity (ROE).3 This capital inefficiency signals to investors that company assets are not being optimally utilized to generate returns. The management teams in South Korea have historically grappled with an understanding of efficient capital allocation, particularly in a low-growth environment following decades of rapid expansion.3 This legacy mindset has led to a preference for hoarding cash rather than investing in growth opportunities or returning capital to shareholders through dividends or share buybacks. The combination of low dividend payouts, inefficient use of capital, and a focus on control rather than shareholder value creates a less attractive investment proposition, directly contributing to the persistent undervaluation observed in the "Korea Discount."
2. The Role of Taxation in the "Korea Discount" The tax regime governing investment income in South Korea plays a substantial role in the "Korea Discount," particularly concerning dividend taxation. A comparative analysis with global trends, especially the U.S. perspective, highlights how South Korea's tax structure can disincentivize equity investment and shareholder returns. 2.1 South Korea's Dividend Tax Structure for Individuals South Korea's individual dividend tax structure is characterized by a progressive rate system that can result in a high overall tax burden, especially for larger investors. For resident individuals, dividends and interest income below KRW 20 million (approximately $14,700 annually) are generally subject to a 14% withholding tax (WHT), with an additional 10% local income tax, totaling an effective rate of 15.4%.8 However, for dividend and interest income exceeding this threshold, the tax burden significantly increases, subjecting it to progressive rates ranging from 6% to 45%.8 When the 10% local surtax is included, the maximum effective tax rate can reach as high as 49.5%.8 This steep progression creates a significant disincentive for large-scale dividend investing. A broader perspective on the combined tax burden on corporate profits distributed as dividends reveals South Korea's high integrated tax rate. This integrated rate, which accounts for both corporate income tax and individual dividend tax, stands at 59.2% in South Korea.4 This is notably higher than the OECD average of 36.8%.4 For comparison, the United States has an integrated rate of 46.9%, Japan 44.0%, Australia 47.1% (with an imputation system), Canada 55.2% (with an imputation system), Germany 48.4%, France 34%, and the UK 39.35%.4 Some countries like Singapore (17%) and Estonia (20%) have even lower integrated rates, often due to zero dividend tax policies.4 Many developed economies employ dividend imputation systems (e.g., Australia, Canada) or exemption systems (e.g., Singapore) to mitigate or eliminate the double taxation of corporate profits (taxed at the corporate level and again at the individual shareholder level).16 Under an imputation system, shareholders receive a tax credit for the corporate tax already paid, reducing their individual tax liability on dividends. Australia, for instance, offers full imputation, potentially resulting in a tax refund if the individual's marginal tax rate is lower than the corporate rate.18 While South Korea has some elements of a partial imputation system, its overall integrated tax burden remains among the highest globally, acting as a significant disincentive for companies to distribute profits and for investors to seek dividend income.4 2.2 U.S. Dividend Tax Perspective In contrast to South Korea, the United States employs a dividend tax structure designed to incentivize certain types of equity investment through preferential tax rates for "qualified dividends." The U.S. tax system distinguishes between "qualified" and "nonqualified" (or "ordinary") dividends.22 Qualified dividends, which typically come from U.S. corporations or qualifying foreign entities and meet specific holding period requirements, are taxed at lower long-term capital gains rates: 0%, 15%, or 20%, depending on the investor's taxable income and filing status.22 For instance, in 2025, a single filer with taxable income up to $48,350 would pay 0% on qualified dividends, while those with income between $48,351 and $533,400 would pay 15%, and those above $533,401 would pay 20%.22 Nonqualified dividends, on the other hand, are taxed at ordinary income tax rates, which can range from 10% to 37%.22 Beyond federal taxation, dividend income in the U.S. may also be subject to state-level income taxes, which vary significantly. Some states, like California (13.3%), Hawaii (11%), and New York (10.9%), have high top income tax rates that would apply to dividend income.26 Conversely, seven states impose no personal income tax at all, including Alaska, Florida, and Nevada.26 Despite these state variations, the combined federal and state dividend tax rate in the U.S. averages around 28.73%.14 This structure, particularly the lower rates for qualified dividends, is designed to encourage long-term equity investment and dividend income, presenting a more favorable environment for shareholders compared to South Korea's higher integrated rates. 2.3 Capital Gains Tax Structure and its Influence The taxation of capital gains also plays a critical role in shaping investor behavior and corporate payout policies. The differences between South Korea and the U.S. in this regard further explain the "Korea Discount." In South Korea, the capital gains tax regime for publicly traded stocks has undergone recent changes. A previously planned introduction of a broad financial investment income tax, which would have applied to capital gains from various financial products for all shareholders, was abolished for 2025.5 This means the existing capital gains tax regime for stocks remains in place, which primarily applies only to "top shareholders".5 For most retail investors, capital gains from listed shares are not subject to a direct capital gains tax, though flexible transaction tax rates apply (0.18% in 2024, decreasing to 0.15% in 2025).5 For individuals who are considered "top shareholders" or for transfers of unlisted shares, capital gains tax rates typically range from 11% to 33% (including local surtax).29 In the U.S., capital gains are taxed differently based on the holding period. Short-term capital gains (from assets held for one year or less) are taxed at ordinary income tax rates. Long-term capital gains (from assets held for more than one year) are taxed at preferential rates of 0%, 15%, or 20%, aligning with the rates for qualified dividends.22 The disparity in capital gains taxation significantly influences investor behavior in South Korea. The combination of high progressive dividend tax rates and the absence of a broad capital gains tax for most retail investors creates a strong incentive for investors to prefer capital appreciation over dividend income.8 This tax arbitrage encourages companies to retain earnings or engage in share buybacks rather than distributing dividends, as buybacks can allow for greater deferral of capital gains tax for shareholders who do not tender their shares.30 This dynamic contributes to the low dividend payout ratios and, consequently, the "Korea Discount." 2.4 Comparison of Tax Systems and their Impact on Payout Policy Tax systems globally adopt different approaches to taxing corporate profits and shareholder income, each with distinct implications for corporate payout policies and market valuations. Classical System: Under a classical tax system, corporations and their shareholders are treated as separate tax entities. This results in double taxation: corporate profits are taxed at the company level, and then distributed profits (dividends) are taxed again at the individual shareholder level as part of their income.16 The U.S. traditionally operates under a classical system, though it partially mitigates double taxation by applying lower preferential rates to qualified dividends and long-term capital gains.20 Imputation System: Countries like Australia and Canada employ an imputation system. This approach aims to reduce or eliminate double taxation by attributing some or all of the corporate tax paid to the shareholders through a tax credit.16 For example, Australia's full imputation system ensures that the total tax paid on corporate profits, at both corporate and shareholder levels, equals the shareholder's marginal tax rate. This can even result in a tax refund for individuals whose marginal rate is lower than the corporate tax rate.18 Canada uses a partial imputation system.20 Exemption System: Some jurisdictions, such as Singapore, utilize an exemption system where dividends are not taxed at the individual level if corporate tax has already been paid on the profits.4 This effectively eliminates double taxation on distributed profits. South Korea's tax system, despite some elements of partial imputation, results in one of the highest integrated tax burdens globally when corporate and individual dividend taxes are combined.4 This high tax burden acts as a significant disincentive for companies to distribute profits as dividends, as it reduces the net return to shareholders. This disincentive, coupled with the capital gains tax structure that favors capital appreciation for most retail investors, reinforces the preference for retaining earnings or conducting share buybacks over dividend payouts. This ultimately contributes to the low shareholder returns and the persistent "Korea Discount" observed in the market.
3. Government Initiatives and Future Direction Recognizing the multifaceted nature of the "Korea Discount," the South Korean government has initiated a series of reforms aimed at enhancing corporate value, improving shareholder returns, and revitalizing the equity market. These initiatives span corporate governance, tax policy, and broader market development. 3.1 Recent Reforms and "Value-Up Programme" The South Korean government has launched the "Corporate Value-Up Programme" in February 2024, a significant policy push designed to address the undervaluation of Korean companies and boost their market valuations.7 This program aims to improve corporate governance, enhance shareholder returns, and encourage companies to publicly disclose their plans for improving corporate value. It includes tax incentives and promotes the voluntary adoption of higher governance standards.7 This initiative mirrors a successful program implemented by the Tokyo Stock Exchange in April 2023, which contributed to the Nikkei 225 index reaching a new record high.1 Complementing this, the National Assembly recently passed a revision to the Commercial Act. This amendment is specifically designed to enhance corporate governance and strengthen minority shareholder rights, particularly by targeting egregious group restructurings that have historically favored controlling shareholders at the expense of minority investors.6 The immediate impact is expected to curb such practices and foster a gradual shift in corporate governance culture.6 However, the long-term effectiveness of this law will depend significantly on its judicial interpretation and enforcement.6 These reforms have already had a tangible impact on market sentiment. The Korean Stock Exchange (KOSPI) has seen a substantial rise, increasing by 33% year-to-date and nearing an all-time high, driven by investor optimism surrounding these governance improvements.6 This positive market response underscores the market's sensitivity to genuine efforts to address long-standing structural issues. 3.2 Proposed Tax Reforms for Dividends A key component of the government's strategy to mitigate the "Korea Discount" involves reforming the dividend tax system to make dividend income more attractive to investors. The South Korean government plans to lower individual dividend tax rates for listed companies, proposing a new separate taxation system that would apply rates of 10-20%, down from the current progressive rates that can reach 6-45%.8 This new system is specifically designed to ease the steep tax burden on dividend income exceeding KRW 20 million (approximately $14,700).8 The proposal suggests applying these lower rates to dividend income from companies that maintain a dividend payout ratio above a certain threshold, initially proposed at 35% and potentially increasing to 40%, or for companies that have demonstrated an increase in dividends compared to their average over the past three years.8 This policy shift is supported by President Lee Jae-myung, despite previous political opposition that characterized similar moves as "tax cuts for the rich".8 The objective behind these proposed tax cuts is clear: to encourage dividend investing, prompt companies to increase their dividend payouts, and ultimately attract more capital into the domestic stock market.8 If effectively implemented, these reforms could significantly alter corporate payout policies and enhance shareholder returns, thereby directly addressing a core driver of the "Korea Discount." 3.3 Addressing Capital Gains Tax for Retail Investors Beyond dividend taxation, the South Korean government is also adjusting its approach to capital gains tax for retail investors to further encourage participation and investment in the stock market. A notable recent development is the abolition of the planned Financial Investment Income Tax for 2025. This tax, which would have imposed capital gains taxes on a broader range of financial products, including virtual assets, for all shareholders, was originally scheduled for implementation in 2025.5 Its abolition means that the existing capital gains tax regime for publicly traded stocks will remain in place, which primarily taxes only "top shareholders".5 This decision was made to protect domestic investors and foster the development of the capital markets.27 Furthermore, the government is reducing securities transaction taxes. The tax rate on transactions made on the Kospi and Kosdaq markets is being cut to 0.18% in 2024 and further to 0.15% in 2025, down from 0.20% in 2023.5 These reductions in transaction costs, coupled with the limited application of capital gains tax for most retail investors, are designed to make stock market investment more attractive and accessible, encouraging greater retail participation and liquidity. 3.4 Broader Market Development and Inheritance Tax Beyond direct tax and governance reforms, the South Korean government is also addressing broader structural issues and market infrastructure to enhance the appeal of its equity market. A significant long-standing issue is the high inheritance tax, which can range from 50% to 60%.1 This heavy tax burden disproportionately affects Chaebol families, leading to the erosion of their ownership stakes across generations. This, in turn, influences their business decisions, often leading them to prioritize maintaining control over maximizing shareholder value, as they seek to preserve family ownership against the impact of inheritance taxes.1 President Yoon has emphasized the need to reduce this burden, recognizing its impact on corporate behavior and market dynamics.1 In terms of market infrastructure, the Financial Services Commission (FSC) is encouraging the Korea Exchange to publish lists of companies' Price-to-Book Ratios (PBRs) by sector. This aims to increase transparency and allow investors to more easily identify companies trading below their book value.5 Additionally, the FSC plans to allow brokerage companies to develop index and exchange-traded funds (ETFs) that track companies with high shareholder values, further directing investment towards value-creating firms.5 Plans also include launching alternative trading systems to introduce competition to the Korea Exchange and opening a nighttime derivatives trading market to enhance liquidity and accessibility.5 While these reforms aim to attract more foreign investment, potential external headwinds, such as the implementation of higher U.S. tariffs on South Korea's export-reliant economy, could pose challenges.6 The comprehensive nature of these initiatives reflects a recognition that addressing the "Korea Discount" requires a multi-pronged approach tackling governance, taxation, and market structure. Conclusions and Recommendations The "Korea Discount" is a complex and deeply entrenched market phenomenon, characterized by the persistent undervaluation of South Korean equities relative to global peers. This analysis confirms that the primary drivers are not geopolitical risks, but rather systemic issues related to corporate governance deficiencies, particularly within Chaebol structures, and a tax regime that disincentivizes shareholder returns. South Korea's exceptionally high integrated tax rate on dividends, coupled with a capital gains tax structure that historically favored capital appreciation for most retail investors, has played a significant role in fostering low dividend payout ratios and inefficient capital allocation by corporations. The South Korean government's recent initiatives, including the "Corporate Value-Up Programme" and revisions to the Commercial Act, represent crucial steps towards addressing these long-standing issues. The positive market response, evidenced by the KOSPI's recent surge, underscores the potential for these reforms to instill greater investor confidence. The proposed tax reforms aimed at lowering individual dividend tax rates are also a welcome development, signaling a commitment to a more shareholder-friendly environment. To fully overcome the "Korea Discount" and foster a vibrant, globally competitive equity market, the following recommendations are critical: Recommendations for South Korea: ⦁ Strengthen Corporate Governance Enforcement: While legislative changes like the Commercial Act revision are positive, their long-term effectiveness hinges on robust enforcement and clear, consistent judicial interpretation. Continued efforts are needed to reduce the disproportionate influence of controlling shareholders, potentially through mechanisms such as cumulative voting or expanding the "3% rule" to more audit committee members, as these issues may still require further attention.7 This will help ensure that corporate decisions genuinely align with the interests of all shareholders, not just a select few. ⦁ Optimize Tax Policies to Incentivize Dividends: The proposed separate taxation system for dividends is a step in the right direction. It is imperative that this reform is implemented effectively to genuinely incentivize increased dividend payouts, rather than inadvertently benefiting only existing high-payout firms. South Korea should further explore aligning its dividend tax system with international best practices, such as adopting a full imputation system (like Australia) or an exemption system (like Singapore). Such changes would significantly reduce or eliminate double taxation, making Korean equities more attractive to both domestic and foreign capital. ⦁ Address Inheritance Tax Burden: The high inheritance tax rates significantly impact Chaebol families, often leading them to prioritize control preservation over maximizing shareholder value. Continued efforts to reduce this burden are essential to encourage controlling shareholders to adopt more shareholder-centric strategies and unlock corporate value. ⦁ Enhance Market Transparency and Liquidity: Continued development of market infrastructure is vital. Initiatives like encouraging the Korea Exchange to publish PBR lists, enabling brokerages to develop ETFs tracking high shareholder value companies, and fostering alternative trading systems will enhance transparency, liquidity, and investor access.5 ⦁ Proactive International Engagement: South Korea must remain vigilant and proactive in monitoring and mitigating external economic headwinds, such as potential trade tariffs from major partners like the U.S..6 Maintaining open dialogue and strategic economic partnerships will be crucial for the stability and growth of its export-reliant economy and, by extension, its equity market. U.S. Perspective: For U.S. investors, the ongoing reforms in South Korea, particularly those aimed at improving corporate governance and increasing shareholder returns, present a potentially compelling investment narrative. If South Korean companies genuinely increase dividend payouts and improve capital allocation, and if the Korean tax burden on dividends is effectively reduced, the U.S. tax system's preferential rates for qualified dividends and long-term capital gains could make these investments particularly attractive. This could lead to increased capital flows from the U.S. into the South Korean market, contributing to the long-awaited unwinding of the "Korea Discount." 참고 자료
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