Seoul Administrative Court 2012Guhap39353 (26 July 2013)

If there is no tax payable due to the mixture of direct foreign tax credit and indirect foreign tax credit, the under-reported additional tax is levied.

(1) If a domestic corporation without a foreign subsidiary calculates the foreign tax credit, and the remaining tax amount remaining after mixing the foreign tax credit method and the indirect foreign tax credit method under paragraph (4) is maintained in the calculation of losses in the settlement of accounts, and there is no tax amount to be paid after fully deducting the calculated tax amount, the disposition of imposing the under-reported additional tax.

Article 57 (Foreign Tax Credit, etc.)

2013Nu24367 Revocation of Disposition of Corporate Tax Imposition

Korea AAA Development Corporation

Head of △ District Office

Seoul Administrative Court Decision 2012Guhap39353 decided July 26, 2013

February 20, 2014

March 6, 2014

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The judgment of the first instance shall be revoked. The defendant shall revoke the imposition of the corporate tax of 000 won for the year 2008 and the corporate tax of 000 won for the year 2009 on April 5, 2013.

(cite of the judgment of the first instance)