In 2022, less than 10 Supreme Court’s Decisions pronounced, which include the issues of the Framework Act on National Taxes(“FANT”) and were published in the Judgement Gazette. Among them, this article is focusing on the 4 meaningful cases.
 First, “Supreme Court’s Decision August 25, 2022, 2017du41313”, reaffirms the position of existing precedents on the requirements and criteria for reorganizing transactions to deny a circumvention transactions or multi-level transactions for the purpose of tax evasion under Article 14(3) of the FANT. The decision is valid as it applies the principle of substantive taxation principle on circumventive or pyramid transactions in relation to calculating the tax base.
 “Supreme Court Decision May 26, 2022, 2022du32825”, reaffirms the position of existing precedents that determine the existence of fraud based on whether the counterparty files the VAT return, pays or refunds VAT. According to these precedents, even though the same taxpayers engaged in the same fictitious transaction, in the case of corporate tax, the taxpayer’s actions alone are used to determine whether fraud is committed, otherwise in the case of VAT, in addition to the taxpayer’s actions whether the taxpayer is aware that the taxpayer’s deduction of VAT will result in a decrease in national tax revenue. However, this decision is not justifiable as it violate tax jurisprudence because (1) it applies different criteria for different tax categories without any reasonable basis, despite the fact that the relevant regulations stipulate ‘fraud’ in the same way regardless of the tax category, and (2) despite the fact that the statute does not require such an additional requirement for long-term limitation for imposition of VAT, the decision requires the subjective requirement (i.e., recognition of the fact that it will result in a decrease in the national tax revenue) only in the case of VAT,.
 On the other hand, “Supreme Court Decision May 26, 2022, 2019du60226”, regarding whether an investor in an Fisheries Partnership are an ‘oligopolistic stockholder’ who is liable for secondary tax, held that an investor in an Fisheries Partnership cannot be such an ‘oligopolistic stockholder’ because he is not a stockholder or a partner in corporations. This decision is justified in light of the principle of strict interpretation of tax laws.
 Lastly, “Supreme Court Decision January 14, 2022, 2017du41108” is the first decision to explicitly determine that the reference point for determining whether there is a justifiable reason to exempt the penalty tax is the deadline for filing and paying taxes under the each tax law.