As revision of tax Convention between the Republic Korea and Japan, the articles not decided in details may cause a problem in the process of changing the existing Korean and Japanese tax’s frame. This is not only the problem between domestic, but a...
As revision of tax Convention between the Republic Korea and Japan, the articles not decided in details may cause a problem in the process of changing the existing Korean and Japanese tax’s frame. This is not only the problem between domestic, but also the problem between Korea and Japan, Contracting State.
We try to analyze the problem in connection with recognition of revenue and expense and present to a alternative plan.
1. The recognition of revenues subject to attribution principle
1) The problem and alternative plan subject to the method for recognition of revenue reverted to permanent establishment
2) Classification between wholesale income and commission income
3) Classification of revenue from plant installation project service
2. Distribution subject subject to attribution principle
1) Applicability of announcement by the Office of National Tax Administration about distribution
2) Dealing with class B payroll taxes
3) Denying branch’s expenditure for purchasing by the head office