TITLE	Supreme Court Decision 2020Du47397 Decided October 27, 2022 ¡¼Cancellation of Disposition Denying the Request for Correction for the Application of Restrictive Tax Rates¡½ [full Text]
Summary
¡¼Main Issue and Holding¡½ In a case where a foreign investment scheme constitutes ¡°a foreign corporation to which the domestic source income actually reverts¡± pursuant to Article 98-6(1) of the former Corporate Tax Act, whether the said foreign investment scheme may file a request for correction to satisfy the eligibility requirements for the application of restrictive tax rates under a tax treaty in accordance with Article 98-6(4) of the former Corporate Tax Act (affirmative)

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