TITLE	¡¼Syllabus of Latest Opinion¡½ Supreme Court Decision 2026Du30340 Decided June 25, 2026 ¡¼Revocation of Disposition Refusing to Correct Corporate Tax¡½ [full Text]
Summary
¡¼Main Issues and Holdings¡½ [1] Method of calculating ¡°foreign source income¡± pursuant to Article 57(1)1 of the former Corporate Tax Act where the income amount of a certain country is in a deficit when determining the credit limit of tax paid overseas of a domestic corporation having two or more overseas places of business [2] Whether Article 4 of the Second Protocol to the Agreement Between the Government of the Republic of Korea and the Government of the People¡¯s Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, while setting forth the general principle that a foreign tax credit should be allowed as a method to prevent double taxation for Korean residents, can be seen to stipulate that specific credit methods, scope, etc., should be governed by Korean tax laws (affirmative)

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