(1) If a foreign corporation or foreign investment vehicle receives domestic source income pursuant to Article 93 through a foreigner consolidated account (referring to an account opened by a foreign financial investment entity, in its own name, provided in Article 12 (2) 1 (b) of Financial Investment Services and Capital Markets Act to collectively order and settle stock purchase and sale transactions of other foreign investors; hereinafter the same shall apply), the person who pays such domestic source income through the foreigner consolidated account shall withhold corporate tax at the amount specified in each subparagraph of Article 98 (1) when paying the income to the holder of the foreigner integrated account.
(2) A foreign corporation or foreign investment vehicle that receives income under paragraph (1) may file a claim for rectification with the head of the tax office having jurisdiction over the place of tax payment to be applied non-taxation, tax exemption, or limited tax rates under a tax treaty.
(3) Article 98-4 (5) through (7) and Article 98-6 (4) through (6) shall apply mutatis mutandis to the deadline, method, and procedures for filing a claim for rectification under paragraph (2). In such cases, "real beneficiary" and "real beneficiary or income payer" in the main clause of Article 98-4 (5), and "real beneficiary" and "real beneficiary or the person liable for withholding tax" in the main clause of Article 98-6 (4) shall be construed as "foreign corporation or foreign investment vehicle" respectively.[This Article Added on Dec. 31, 2023]