SNU Big Data Knowledge Information Platform
Full Menu
AI
Your Browsing History
13 More
loading...
Report registration
Paper List
외국법인 국내지점에 대한 과소자본세제의적용에 따른 한도초과이자의 소득구분 - 대법원 2018. 2. 28. 선고 2015두2710 판결과 관련하여 -
Author
임재혁
Journal Title
조세학술논집
Publication Year
2018
Topics
Summary
The Supreme Court decision classified an amount exceeding the thin capitalization limit as dividend income under Korean tax law and interest income under the Korea-Singapore Tax Treaty. However, this is argued to be inconsistent with existing precedents recognizing the priority of tax treaties over domestic law and the principle of treaty observance. Therefore, the income classification of excess interest subject to thin capitalization should be determined in accordance with the tax treaty.
Related Content
LikeSNU analyzes your query semantically to recommend related resources.
Previous
Next