Company housing can be excluded from holding tax if filed by September 30

This guide is for companies in Korea that own housing for employees, and for the staff who handle their property tax. Staff housing (사원용주택) and dormitories (기숙사) can be left out of the Comprehensive Real Estate Holding Tax (종합부동산세) billed in December, but only if you file an exclusion report (합산배제 신고) between September 16 and 30.

The filing window: September 16 to 30

Under Article 8(3) of the Comprehensive Real Estate Holding Tax Act (종합부동산세법), you report your holdings to the head of the competent tax office (관할세무서장) from September 16 to September 30 each year.

In 2026, September 30 is a Wednesday, so the deadline does not move to the next day. The Chuseok holiday runs from Thursday, September 24 to Saturday, September 26, with no substitute holiday. From September 17 there are eight working days: September 17, 18, 21, 22, 23, 28, 29 and 30.

Missing the window brings no penalty tax (가산세), because the exclusion is an application, not a duty. But houses you could have excluded stay in the tax base for the December bill.

Staff housing: three requirements, two exclusions

Article 8(2), item 2 of the Act excludes "dormitories and staff housing provided for employees' residence" and leaves the scope to Article 4 of the Enforcement Decree. The Decree was amended on February 27, 2026 by Presidential Decree No. 36132, and Article 4 now has 27 items in force. Companies normally use item 1 (staff housing) and item 2 (dormitories).

Article 4(1), item 1 sets three requirements for staff housing:

• Provided to employees free of charge or at low cost.
• Owned by the employer, including houses owned by an in-house welfare fund (사내근로복지기금) or a joint welfare fund (공동근로복지기금).
• Within national housing size (국민주택규모), or with an official price (공시가격) of ₩600 million or less on the tax base date (과세기준일).

A house over 85 m² still qualifies if its official price is ₩600 million or less. Article 2(6) of the Housing Act (주택법) defines national housing size as an exclusive residential area of 85 m² or less, or 100 m² or less in eup and myeon areas (읍·면) outside the Seoul metropolitan area (수도권) that are not urban areas.

Its proviso excludes two cases:

• Individual employer: a house given to an employee who is a relative under the Framework Act on National Taxes Enforcement Decree, Article 1-2(1) (국세기본법 시행령).
• Corporate employer: a house given to an officer who is a shareholder or investor, unless the officer is a minority shareholder (소액주주등) under the Corporate Tax Act Enforcement Decree, Article 50(2) (법인세법 시행령).

A CEO who holds shares and lives in company housing is caught by this proviso. Check each officer's shareholding and minority status first.

The low-cost test and dormitories

Article 2-3 of the Enforcement Rule sets the low-cost line. The jeonse deposit (전세금, a lump-sum lease deposit) or rental deposit (임대보증금) on the tax base date must be 10/100 or less of the official price. If the employee pays monthly rent, convert one year of rent at the one-year term deposit rate under the VAT Act Enforcement Rule, Article 47 (부가가치세법 시행규칙) and add it to the deposit before comparing. For a house with an official price of ₩500 million, the line is ₩50 million including converted rent. Above it, the house is not staff housing.

For dormitories, Article 4(1), item 2 of the Decree refers only to "dormitories under the Building Act Enforcement Decree, Appendix 1, item 2(d)" (건축법 시행령 별표 1 제2호 라목). There, a general dormitory serves students or employees of schools, factories and the like, and households using shared cooking facilities make up 50% or more of all households. If the building register (건축물대장) lists the building as multi-household housing (다가구주택) or multiplex housing (다세대주택), item 2 does not apply. Test the staff housing rules instead.

Houses that stood empty

The tax base date is June 1. Article 4(2) of the Decree, added on February 28, 2025, covers gaps between occupants: a house provided to employees for 9 months or more in the year, and not used for anything else while it was not provided, counts as provided on the tax base date.

Both conditions apply. A house used as storage or office space during three empty months loses this rule, so keep a record of how it was used while empty.

The cost of missing the filing

The bases are Article 8(1), item 2, Article 9(2), item 3 and the proviso to Article 10 of the Act, in force since January 1, 2026 under Act No. 21224, and Article 2-4(1) of the Decree.

With a ₩0 basic deduction, tax starts from the first won of the official price. With no cap, there is no relief even if the tax multiplies over the previous year. If two company houses are left out, 60% of their combined official prices is taxed in full at 2.7%.

Forms and the September timeline

Article 2(4) of the Enforcement Rule assigns one form to each item, as amended by Ministry of Finance and Economy Ordinance No. 16 (재정경제부령 제16호) on March 20, 2026:

A company with both staff housing and dormitories files two forms; they cannot be combined.

Form No. 28 is a separate filing. Public-interest corporations (공익법인등), public housing operators (공공주택사업자), housing associations (주택조합), redevelopment operators (정비사업시행자), private construction rental operators (민간건설임대주택사업자), urban development operators (도시개발사업시행자), social enterprises (사회적기업등) and clans (종중) can use the general progressive rates instead of the single rate. They file Form No. 28 (법인 주택분 종합부동산세 일반 누진세율 적용 신고서) in the same September 16, 30 window, with proof of status such as a public-interest corporation confirmation, project plan approval, rental business registration certificate, copy of the articles or bylaws, or establishment permit. Filing the exclusion does not cover this; the forms and legal bases differ.

Working back from September 30, 2026:

Re-filing and recapture

Under the proviso to Article 4(5) of the Decree, from the year after your first filing you need not file again unless something changed. Article 2(5) of the Enforcement Rule, added on March 21, 2025, defines a change:

• the ownership or exclusive area of the house;
• for staff housing only, the deposit under Article 2-3 of the Enforcement Rule.

The deposit item is new. Raising only the deposit at renewal is a change, and if the deposit now exceeds 10% of the official price you must file again.

The National Tax Service (국세청) says that if a house is later found not to meet the requirements, it can collect the excluded tax plus an interest-equivalent charge (이자상당가산액). Company housing typically fails in three ways: an officer or the officer's relative moves in after the employee leaves; the deposit is raised above the 10% line; or the empty house is used for something else. Reflect any of these in the next year's filing.

Checklist

• Judge each house by its status on June 1.
• List every house the company owns.
• Sort dormitories from houses by building register use.
• Pick the size test or the ₩600 million price test for each house.
• Find occupants who are shareholder or investor officers.
• Check their minority shareholder status.
• Add converted monthly rent to the deposit.
• Confirm the total is 10% or less of the official price.
• Confirm 9 or more months of provision.
• Confirm no other use while empty.
• Check deposit changes on houses filed before.
• Check whether Form No. 28 applies.
• Prepare supporting documents for each form.
• Print and keep the filing receipt.