법조 제75권 제3호(통권 제777호) 판례평석 - 482 - precedents. That is, the position of the lower court is not correct. Furthermore, the SCK did not point out the error in the lower court’s judgment. The issue described above stems from the wording of Article 89, Paragraph 2, Item 2 of the Enforcement Decree of the CITA. This is because the aforementioned provision applies the supplementary valuation method, regardless of the location of the asset. To resolve this, it is necessary to interpret the provision in a systematic and purpose-oriented way. Furthermore, the relevant articles of the Enforcement Decree of the CITA should be amended to allow the valuation methods of Article 58-3 of the Enforcement Decree of the IGTA or the arm’s length price methods of the AITA to be applied to overseas assets.
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