08 December 2017

Korean Supreme Court rules on permanent establishment of foreign private equity fund

The Korean Supreme Court (the Supreme Court) recently issued a decision on whether a foreign private equity fund (the Fund) had a permanent establishment (PE) in Korea. The Supreme Court ruled that the Fund did not have a PE in Korea, where investment supporting activities were performed by the directors of the Korean subsidiaries (the Korean Advisors) of the Fund's foreign general partner (the GP).

A Global Tax Alert, attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2017-2087

Document ID: 2017-2087