TITLE	¡¼Syllabus of Latest Opinion¡½ Supreme Court Decision 2021Du36202 Decided November 6, 2025 ¡¼Revocation of Disposition of Collection of (Withholding) Corporate Tax¡½ [full Text]
Summary
¡¼Main Issues and Holdings¡½ In a case where Incorporated Company A, a foreign-invested enterprise engaging in a business eligible for tax reduction and exemption under the former Act on Restriction on Special Cases Concerning Taxation, paid dividends to foreign investors, and dispute arose regarding the method of calculating the amount of withholding corporate tax on dividends, the case affirming the lower judgment, which held that ¡°the amount obtained by applying the withholding tax rate of 20% under the former Corporate Tax Act to the taxable portion of the dividends after the granting of tax reduction and exemption pursuant to Article 121-2(3) of the former Act on Restriction on Special Cases Concerning Taxation¡± should be deemed the amount of withholding tax payable by Company A, on the grounds that such amount does not exceed ¡°5% of the total dividends,¡± the maximum tax rate on dividend income prescribed in the Convention between the Republic of Korea and Hungary for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income

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