• Type: KPMG information, Press release
  • Date: 7/15/2013

Tax Brief 2013 June 

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I. Tax Trend
Is deemed gift tax imposition on ‘Unfair funneling of work to subsidiaries’ a violation of the constitution?


II. Recent major tax court cases and authoritative rulings
(1) Taxability on capital gains from the land upon condemnation and the recognition period for the liquidation proceed (Bubkyububin 2013-41, 2013.3.28)
(2) Calculation of a resident’s dividend income received from a private investment special purpose company (Seomyunbubkyu-475, 2013.4.23)
(3) Bad debts tax credit on VAT on receivables conversed to shares upon an approval of corporate reorganization plan (Buga-424, 2013.5.14)
(4) Supply time for installment payments for apartments with previously unsold purchasing rights (Bugagachisaekwa -409, 2013.5.9)


III. Tax Topic
1. Summary
2. Tax credit methods
3. Foreign tax amount eligible for foreign tax credit
4. Conversion of currency of the foreign tax amount (Article 48 of the Enforcement regulation of the Corporate Income
Tax Law)
5. Time of foreign tax payment credit (Article 94, Subparagraph 3 of the Presidential Decree of the Corporate Income Tax Law)