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(영문) 국내 상장주식의 가상주식을 기초자산으로 한 파생금융상품계약 손익의 소득구분
조세심판원 질의회신 | 2011-08-23 | 국제세원관리담당관실-400 | 법인
Document Number

International Tax Institute Management Office-400 ( August 23, 201)

Items of Taxation

A corporation

Journal

Where a domestic corporation enters into a derivatives contract with a foreign corporation operating a non-financial business without a permanent establishment in the Republic of Korea and pays settlement fees to a foreign corporation, the foreign corporation's received fees shall constitute other income in the Republic of Korea.

Congress RESALS

Where a domestic corporation enters into a derivatives contract with a foreign corporation operating a non-financial business that has no permanent establishment in the Republic of Korea, it shall constitute underlying assets of domestic listed stocks owned by such foreign corporation, and where it is required to pay a foreign corporation an adjustment fee in addition to the decline on the contract date according to the base price at a specified point of time in the contract terms and conditions, the consideration received by the foreign corporation shall be other income in the Republic of Korea under subparagraph 10 of Article 93 of the Corporate Tax Act.

Related statutes

Article 93 of the Corporate Tax Act

Main text

1. A summary of the contents of inquiry;

The income classification of the amount of derivatives loss that a domestic corporation (B) pays to a foreign corporation to the foreign corporation (A) at the time of settlement due to a decline in the domestic funeral (A) price by the difference settlement type contract.

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