According to recent reports, the South Korean Tax Tribunal issued a judgment in August 2023 concerning the obligation of a Korean licensee to withhold tax on license fees (patent royalties) paid to a U.S. licensor. The license fees were paid during the period 2018 to 2022, on which the licensee withheld tax at a rate of 15% as provided for in Article 14 (Royalties) of the 1976 South Korea-U.S. tax treaty. After the tax was withheld, the U.S. licensor claimed a refund of the tax withheld, whic…