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TITLE Supreme Court Decision 2023Du44634 Decided January 11, 2024 ¡¼Revocation of Disposition Refusing Correction of Local Corporate Income Tax¡½ [full Text]
Summary
¡¼Main Issue and Holding¡½ Where the double taxation on the tax paid overseas is not completely avoided on the sole basis of the foreign tax credit system in accordance with the former Corporate Tax Act, whether the amount of the tax paid overseas may be deducted from the amount of the local corporate income tax on the basis of 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 (negative)
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