A Comparison between EU and South Korean VAT from a Legal Transplants Perspective¹

South Korea introduced VAT in 1977 and the Sixth VAT Directive was enacted n the same year. In this article, the EU and Korean VAT systems are compared and analysed from a legal transplants perspective. The first research question pertains to whether there was any European influence on the Korean VAT Act at the time of its introduction, and, if so, how this influence was exerted. The second research question concerns the identification and explanation of similarities and differences between the two systems, both at the time of the introduction of Korean VAT and today. This leads to the third research question, whether the two VAT systems have moved towards or away from each other. The analysis has been carried out from a legal transplants’ perspective, which analyses whether, how and why such laws spread across the globe. The article ends with a final analysis and conclusions. Our conclusions are that there was a European influence on the Korean VAT Act by the time of its introduction, that many similarities are so close that they can hardly have occurred spontaneously, and that the two systems have drifted apart from each other.