- Sales support services provided by the taxpayer were subject to zero rate of value added tax (VAT)
- The taxpayer, a subsidiary of a German parent company, provided sales support services to the parent company
- The parent company registered a permanent establishment (PE) in Korea
- The taxpayer reported a zero rate of VAT for the service fees received from the parent company
- The tax authority claimed that the service fees were subject to 10% VAT
- The Tax Tribunal agreed with the taxpayer that the service fees were subject to zero rate of VAT
- The services were considered business support services provided to the parent company.
Source: kpmg.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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