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An old tale with some new perspectives electrónico on taxation of royalty income relating to US-registered patents under the Korea-US Tax Treaty Ji-Hyun Yoon

By: Yoon, Ji Hyun.
Material type: ArticleArticlePublisher: 2021Subject(s): PATENTES | IMPUESTOS | CONVENIOS | TRATADOS INTERNACIONALES | COREA DEL SUR | ESTADOS UNIDOS In: Asia - Pacific Tax Bulletin v. 27, n. 2, 2021, 8 p.Summary: The article focuses on a long-standing conflict between the Korean tax authorities and the courts in respect of "royalties" as prescribed by the tax treaty between the Republic of Korea and the United States. In this specific but significant set of circumstances, a Korean resident manufactures certain goods with a view to selling them in the US market, and in the course of its manufacturing, infringes upon a US patent. Disputes have arisen as to the source and nature of the arising cross-border payments.
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Recursos electrónicos IEF
IEF
APTB/2021/2-5 (Browse shelf) Available APTB/2021/2-5

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Resumen.

The article focuses on a long-standing conflict between the Korean tax authorities and the courts in respect of "royalties" as prescribed by the tax treaty between the Republic of Korea and the United States. In this specific but significant set of circumstances, a Korean resident manufactures certain goods with a view to selling them in the US market, and in the course of its manufacturing, infringes upon a US patent. Disputes have arisen as to the source and nature of the arising cross-border payments.

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