TITLE	Supreme Court Decision 2010Du11948 Decided April 26, 2012 [Revocation of Imposition of Corporate Tax] [full Text]
Summary
[1] Whether the principle of taxation on actual income owners under Article 14(1) of the former Framework Act on National Taxes applies in interpretation and application of tax treaty which is valid as law(=affirmative in principle) [2] Where English limited partnership Gap invested in domestic real estate through Belgian corporation, which generated transfer income, and tax authorities deemed Gap as transfer income owner and imposed corporate tax on Gap, the case affirming the judgment below that if Gap is deemed as actual transfer income owner, it does not violate the nondiscrimination principle of tax treaty [3] Whether Article 132(10)2 of the former Enforcement Decree of Corporate Tax Act is invalid because of deviation from delegation scope by the mother law(negative)

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