º»¹® ¹Ù·Î°¡±â ÁÖ¸Þ´º·Î ¹Ù·Î°¡±â
All
TITLE Supreme Court Decision 2014Du8896 Decided January 14, 2016¡¼ Revocation of Disposition Imposing Corporate Tax¡½ [full Text]
Summary
[1] Meaning and method of determining ¡°actual business management place¡± under Article 1 subparags. 1 and 3 of the former Corporate Tax Act, which is one of the standards for classifying a domestic corporation and a foreign corporation
In case where a corporation, whose actual business management place is based abroad, only carried out specific business activities in the Republic of Korea for a short period, whether the corporation can be deemed as having relocated the actual business management place to the Republic of Korea (negative in principle)
[2] Elements to deem that a Singapore corporation¡¯s fixed place of business (also referred to as ¡°permanent establishment¡±) is located in the Republic of Korea and that it operates the fixed place of business in the Republic of Korea through a dependent agent, and method of determining whether business activities carried out are essential and important
In case where a Singapore corporation¡¯s business activities conducted through a fixed place of business or an agent in the Republic of Korea are merely preparatory or auxiliary in nature, whether the Singapore corporation can be seen as operating a deemed permanent establishment through a fixed place of business or a dependent agent in the Republic of Korea (negative)
Prev Supreme Court Decision 2015Da207747 Decided January 28, 2016¡¼Judgment Execution¡½
Next Supreme Court Order 2014Ma1157 Dated December 29, 2015¡¼Rehabilitation¡½
219 Seocho-ro,Seocho-gu,Seoul 06590,Republic of Korea 02-3480-1100