On 10 July 2014, the South Korean Supreme Court issued its decision on whether a Dutch BV is the beneficial owner of capital gains on the sale of shares of its Korean subsidiary, or the Dutch BV's French parent company. South Korea has tax treaties with both the Netherlands and France. However, only the Netherlands treaty provides exemption from taxation of capital gains in South Korea. When the capital gains were realized, the Korean tax authorities assessed tax on the gains, asserting that the Dutch BV was a conduit and the French parent was the beneficial owner. On appeal, the...