TITLE	Supreme Court Decision 2021Du46940 Decided January 25, 2024 ¡¼Revocation of Disposition Imposing Corporate Tax¡½ [full Text]
Summary
¡¼Main Issue and Holding¡½ Where, in relation to income arising in the residence country of a foreign corporation and reverting to a permanent establishment of the foreign corporation located in the Republic of Korea, under the interpretation of the tax treaty concluded with the residence country, the Republic of Korea may exercise the authority to impose taxes first, and, according thereto, double taxation is adjusted in the residence country, whether the amount of tax paid to the residence country in relation to such income may be subject to tax credits on tax paid overseas under Articles 97(1) and 57(1)1 of the former Corporate Tax Act (negative)

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