Gwangju High Court-2015-Nu-6292 ( November 12, 2015)

Gwangju District Court-2014-Gu Partnership-335 (Law No. 16, 2015)

The F1 holding fee under the Korea-U.S. Tax Treaty is the user fee income.

It is reasonable to deem that the instant license fee falls under the royalty income from the provision of commercial information and know-how, not the business income from the provision of professional services.

Articles 93 and 98 of the former Corporate Tax Act (Amended by Act No. 11128, Dec. 31, 2011); the Convention between the Government of the Republic of Korea and the United Kingdom for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Transfer Income between the Government of the Republic of Korea and the United Kingdom Government

2015du58362 Disposition of revocation of revocation of corporate tax rectification

AA

00. Head of tax office

Gwangju High Court Decision 2015Nu6292 Decided November 12, 2015

March 24, 2016

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The records of this case and the judgment of the court below and the grounds of appeal were examined, but the grounds of appeal by appellant are examined.

The head of the Supreme Court is deemed to have not included the grounds provided for in each subparagraph of Article 4(1) of the Act on Special Cases concerning the Procedure for Appeal. Accordingly, the appeal is dismissed pursuant to Article 5 of the same Act, and the costs of appeal are assessed against the losing party. It is so decided as per