1. Of the judgment of the first instance court, the part against the defendant in excess of the order to revoke below shall be revoked and that part.

1. The reasoning of the judgment of this court citing the judgment of the court of first instance is as follows:

2. Prior to the “legal nature of the instant disposition”, the judgment of the first instance court is dismissed as follows, and the determination on the Defendant’s assertion is added in the next paragraph. As such, the pertinent part is cited in accordance with Article 8(2) of the Administrative Litigation Act, the main text of Article 420 of the Civil Procedure Act, and Article 8(2) of the Administrative Litigation Act, and Article 420 of the Civil Procedure Act.

10 The following shall be added to the 1st day following:

With respect to the income accrued abroad of a domestic corporation, the domestic corporation's income is added to the domestic corporation's income and at the same time, the domestic corporation's income tax, such as corporate tax, is also paid in the relevant source country. Thus, if the entire income taxed in a foreign country is added to the domestic corporation's income for the relevant business year, the corporation

In order to coordinate this, the former Corporate Tax Act provides a foreign tax credit system. In light of the purport of the provision, it is interpreted that the foreign tax credit is not the total amount of tax paid or payable in foreign countries, but the tax amount payable in Korea on foreign source income.

Therefore, when calculating the limit of deduction amount, "foreign source income", which is the molecule, should be based on foreign source income calculated in accordance with Korean tax law. In such cases, "income" should be calculated by deducting the total amount of deductible expenses from the total amount of gross income for the pertinent business year in accordance with Article 14(1) of the former Corporate

Meanwhile, Article 57 (1) 2 of the former Corporate Tax Act provides that the amount of foreign corporate tax paid or payable on income generated from overseas sources may be included in deductible expenses for the purpose of calculating the amount of income for each business year, and the term "foreign source income" in this context is not subject to withholding, but subject to deductible expenses.