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Kim Young-gwon loses final tax lawsuit over 800 million won dispute
South Korean footballer Kim Young-gwon of Ulsan HD has lost a final legal battle against tax authorities regarding a dispute over approximately 830 million won in comprehensive income tax.
The case centered on how foreign tax credits were applied to his income. Kim had previously played in China (2012–2018) and Japan (2019–2021). He attempted to apply unused tax credits from his time in China toward his income earned in Japan to reduce his domestic tax liability in South Korea.
The Ulsan Tax Office rejected this, asserting that under the Income Tax Act Enforcement Decree, tax credits must be calculated and applied separately for each country to prevent excessive credits through low-tax jurisdictions.
Kim challenged the ruling, arguing he was not a South Korean resident during his time in Japan and that the country-specific calculation method was invalid. However, the Supreme Court upheld previous rulings, determining that Kim remained a resident due to his family living in Korea and his income being used for domestic expenses. The court affirmed that tax credits must be managed on a country-by-country basis.
Entities
Kim Young-gwon · Supreme Court of Korea · Ulsan HD · Ulsan Tax Office