South Korean Supreme Court Changes Position on Patents Under Tax Treaty with U.S.

The South Korean Supreme Court issued Decision 2021Du59908 on 18 September 2025 that sets a new precedent on whether royalties paid for patents not registered in South Korea constitute Korean-source income under the 1976 South Korea-U.S. tax treaty. The case arose from a patent infringement dispute that ultimately resulted in the payment of royalties by a Korean company to a U.S. company, on wh…
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