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 a foreign country where a foreign corporation is located and reverting to a permanent establishment of the foreign corporation which is located in the Republic of Korea, in terms of the interpretation of the tax treaty concluded with the foreign country where the foreign corporation is located, the Republic of Korea may exercise the authority to impose taxes first, and double taxation according thereto is adjusted in the foreign country where the foreign corporation is located, whether the amount of tax paid to the foreign country where the foreign corporation is located in relation to the 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

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