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| TITLE | Supreme Court Decision 2008Du9959 Decided May 26, 2011 [Revocation of Disposition of Imposing Corporate Tax] [full Text] |
|---|---|
| Summary | |
| The case affirming the court below's judgment holding that the usance interest which the company Gap paid to the foreign exporter Eul is subject to withholding corporate tax as the payment was an interest income of a foreign exporter accrued inside of Korea, in the case where the general trading company Gap was involved in the export-import transaction of foreign corporations where it imported goods from the foreign exporter Eul which had no domestic permanent establishment in Korea with shipper's usance L/C method and exported them to the third country's foreign importer Byung with a telegraphic transfer method, etc. and received the sales price. The judgment below that the transaction purposed to raise funds under the pretext of a transit trade as the company Gap enjoyed the same effect of borrowing money equivalent to sales price from this transaction is affirmed | |
