The Supreme Court's Second Division, presided over by Justice Oh Kyung-mi, dismissed the appeal by the head of the Yeoksam Tax Office on Oct. 8 without a full review.
The decision cemented two lower court rulings in favor of the Korean unit of the U.S. tech giant.
Tax authorities imposed the corporate and local income taxes in 2020. They took issue with part of Google Korea's domestic advertising revenue which was sent to the group's Singapore-based regional headquarters, Google Asia Pacific, between September 2016 and December 2018.
The authorities classified the payments as taxable royalties for the use of copyrights and know-how.
Google Korea countered that the money was business income of the Singapore entity and therefore beyond Korea's taxing reach, and challenged the levy in court.
The Seoul Administrative Court sided with Google Korea in January 2025, ruling that the payments were not compensation for computer programs, know-how or information on knowledge and experience.
The Seoul High Court upheld the ruling on May 7. It also overturned the lower court's decision on a related local tax claim against the Gangnam-gu Office and dismissed it, saying the local tax would be canceled automatically along with the corporate tax.
The ruling follows a series of court wins by global tech companies against Korean tax authorities.
The Seoul Administrative Court in April canceled 68.7 billion won of about 76.2 billion won in taxes challenged by Netflix Services Korea, in a lower court ruling.
AJP Takeaways
- South Korea's Supreme Court on Oct. 8, 2026 dismissed the Yeoksam Tax Office's appeal without a full review, finalizing Google Korea's win against a tax bill of more than 154 billion won.
- Tax authorities had treated payments Google Korea sent to Singapore-based Google Asia Pacific between September 2016 and December 2018 as taxable royalties. The courts found they could hardly be deemed compensation for know-how.
- The ruling follows the Seoul Administrative Court's decision in April 2026 to cancel 68.7 billion won of a 76.2 billion won tax bill imposed on Netflix Services Korea.
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