TITLE	Supreme Court Decision 2021Du59908 Decided September 18, 2025 ¡¼Revocation of Disposition Refusing the Correction of Tax Assessment¡½ [full Text]
Summary
¡¼Main Issues and Holdings¡½ In a case where a manufacturing method, technology, or information protected by a patent right that is only registered in a foreign jurisdiction but not under domestic law is used in the home country, whether royalty income from such patented method, technology, or information is considered domestic source income (affirmative) Laws and regulations that apply in such cases (held: latter part of the proviso of Article 93 Subparag. 8 of the former Corporate Tax Act) and whether ¡°use¡± stated in the said proviso should be interpreted not as the use of a patent right with exclusive effect itself but as the use of a manufacturing method, technology, and information protected by the said patent right (affirmative)

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