Google Korea Wins Final Victory in 154 Billion Won Corporate Tax Lawsuit

Supreme Court Rejects Tax Authorities' Appeal Without Further Review

Metal fences are installed in front of the Supreme Court in Seocho-gu, Seoul, on July 9, ahead of the Supreme Court ruling in former President Yoon Suk Yeol's obstruction of arrest case. July 9, 2026. Photo by Kang Jin-hyung.

Google Korea has won a final victory in a lawsuit seeking to overturn the tax authorities' collection of approximately 154 billion won in corporate and local income taxes.

According to legal sources on October 12, the Supreme Court's Special Division 2, presided over by Justice Oh Kyung-mi, on October 8 upheld the lower court's ruling in favor of Google Korea in its appeal against the head of the Seoul Yeoksam Tax Office over the collection of corporate taxes and other charges. A dismissal without further review is a procedure under which an appeal is rejected without examining the merits if there are no legally prescribed grounds, such as an error in the interpretation of the law, to overturn the lower court's ruling.

In 2020, the tax authorities had assessed Google Korea approximately 154 billion won in corporate and local income taxes. Google Korea did not withhold taxes on advertising resale fees it paid to Google Asia Pacific, a Singapore-based entity, on the grounds that the fees constituted business income of the Singapore entity and were therefore not subject to taxation in Korea.

The tax authorities, however, determined that the income constituted royalty income taxable in Korea and assessed corporate taxes. Google Korea challenged the assessment and filed a lawsuit. In January 2025, the court of first instance sided with Google Korea and overturned the tax authorities' corporate tax assessment. In May 2026, the appellate court upheld the same decision by dismissing the appeal filed by the head of the Yeoksam Tax Office. However, it overturned the part of the first-instance ruling concerning the head of the Gangnam District Office and dismissed Google Korea's claim against the office.

The reasoning was that, because local income tax is linked to corporate tax, there was no need to separately seek the cancellation of the local income tax assessment against the head of the Gangnam District Office once the corporate tax assessment had been overturned. The tax authorities appealed, but the Supreme Court dismissed the appeal without further review, making Google Korea's victory final.

This content was produced with the assistance of AI translation services.