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외국법인 소속의 기술자로부터 기술용역 공급받고 비용 지급시 대리납부 의무
조세심판원 질의회신 | 1986-07-29 | 부가22601-1551 | 부가
Document Number

Additional 2601-1551 (Law Firm 1986.07.30)

Items of Taxation

Addition

Journal

Where a foreign corporation which has no place of business in the Republic of Korea enters into a technology introduction contract with a foreign corporation which has no place of business in the Republic of Korea and provides technical services stipulated in a contract from a technician belonging to such foreign corporation and pays the technical standby fees and the daily allowances

Congress RESALS

1. In case of re-quality, the payment of the price-added tax shall be made by collecting and paying by proxy the price for the technical service in accordance with Article 34 of the Value-Added Tax Act when considering that the technical service cost is included in the price for the technology service in question and paying a daily allowance to the technician who belongs to the foreign corporation concerned, after concluding a technology introduction contract with the foreign corporation having no place of business in Korea. (2) The daily allowance and the system cost to be paid by the technician dispatched under a contract with the foreign corporation falls under the earned income of the non-resident provided for in subparagraph 7 of Article 134 of the Income Tax Act at the same time constituting a part of the income, or the income of the foreigner dispatched under the technology introduction contract provided for in the Foreign Capital Inducement Act;

Related statutes

Article 34 of the Value-Added Tax Act

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