TITLE	Supreme Court Decision 2009Da79736 Decided November 28, 2013 ¡¼Unjust Enrichment¡½ [full Text]
Summary
Whether a transfer of shares issued by a domestic corporation and owned by a divided corporation to a new corporation established by division pursuant to a foreign corporation¡¯s division constitutes ¡°transfer of shares¡± under Article 13(2) of the ¡°Convention between Japan and the Republic of Korea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income¡± and Article 93 subparag. 10(A) of the former Corporate Tax Act

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