National Tax Service

Basic Tax Rulings for『the
Law for the Coordination of International Tax Affairs』Enforced
From June 15, 2004.

□ The National
Tax Service (Commissioner Yongsup Lee) has issued the

Basic Tax Rulings for『the
Law for the Coordination of International

Tax Affairs』and enforced it from
June 15, 2004.

○ The
Basic Tax Rulings are intended to provide the guideline for interpretation of『the
Law

for the Coordination of International Tax Affairs』in accordance with international

taxation standards, based on implementation experiences and interpretation practices

established since the legislation of the laws (December 6, 1995.)

○ The
NTS formulated the Basic Tax Rulings after inviting various opinions of the
experts

such as taxpayer groups, professionals and public officials concerned
in the international

tax area.

□ The Basic
Tax Rulings can be categorized as follows;

□ Basic Tax
Rulings are administrative regulation made by the commissioner of

the NTS in
order to suggest clear guidelines to tax officials and taxpayers for

the interpretation
and enforcement of tax laws.

○ The
NTS expects that the enforcement of this Basic Tax Rulings will be helpful to
protect

the rights of taxpayers involved in international transactions, including
foreign

corporations,
by reducing the possibilities of arbitrary application
of tax law by the tax

authority and enhancing the consistency and predictability
of taxation.