Article 165-4Exclusion of Foreign Taxes Credited against Income Taxes from Necessary Expenses

If, with regard to the amount of credit-eligible foreign income tax prescribed in Article 165-6, paragraph (1) (Foreign Tax Credit for Nonresidents), a Nonresident is subject to the provisions of that Article or of Article 138, paragraph (1) (Refunding Tax Withheld) as applied mutatis mutandis pursuant to Article 166 (Filing of Returns, Payment of Taxes, and Issuance of Refunds), that amount of credit-eligible foreign income tax is not included in necessary expenses or the amount spent in calculating the Nonresident's real property income, business income, timber income, or miscellaneous income, or occasional income, calculated in accordance with Article 165, paragraph (1) (Calculation of the Tax Base and Amount of Income Taxes Imposed on Aggregate Income) with regard to the Nonresident's income attributable to a permanent establishment.