Greetings from the Global Tax Center of Shin & Kim LLC.
Thank you for the warm reception and strong interest in the inaugural issue of Global Tax Brief.
Global Tax Brief is designed to help businesses respond strategically to a fast-changing global tax landscape. This second issue summarizes the international tax measures in the tax reform bills recently submitted to the National Assembly. We also highlight the key takeaways for multinational enterprises from recent court decisions, Tax Tribunal rulings, and tax authority interpretations.
We hope this issue provides practical guidance to help you manage cross-border tax risks and make timely, informed decisions.
The Global Tax Center of Shin & Kim LLC remains committed to delivering relevant and actionable tax insights for businesses operating globally.
I. Legislative Update – 2026 Tax Reform Proposal (International Tax)
II. Recent Court Decision
(1) Whether a profit-margin-linked true-up payment constitutes royalty income (Supreme Court Decision 2026Du30813 (September 3, 2026))
(2) Per-country limitation applies to carryforwards of foreign tax credits (Supreme Court Decision 2026Du30835 (September 23, 2026))
III. Recent Tax Tribunal Decision
(1) Transfer pricing assessment questioning the functions and risks of overseas subsidiaries and the reasonableness of transfer pricing adjustments (Tax Tribunal Decision 2025Seo2599 (July 2, 2026))
IV. Recent Tax Rulings
(1) Whether the fees paid for an integrated financial portfolio management system constitutes royalty income or business profits (Advance Ruling Sajeon-2026-Beopgyu-Gukjo-0035 (August 24, 2026))
(2) Taxation of distributions from a foreign Exchange-Traded Fund (“ETF”) arising from a return of capital (Ministry of Economy and Finance, Financial Tax Division-576 (June 26, 2026))
(3) Whether consideration paid by a Korean company for personal services performed outside Korea by a non-resident or foreign corporation constitutes Korean-source personal services income and whether it qualifies for tax treaty relief (Written Ruling Seomyeon-2026-Gukje-Sewon-2130 (July 7, 2026))
* For further details, please download the PDF file.
Should you have any questions regarding the above or require further assistance, please do not hesitate to contact us. We would be pleased to provide you with additional information.
