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적격분할 과세특례에 대한 사후관리 위반여부

조세심판원 질의회신 | 2013-07-23 | 법인세과-392 | 법인

Document Number

Corporate Tax and 392 (Law No. 24 July 24, 2013)

Items of Taxation

A corporation

Journal

In applying the applicable post-management of qualified division, it shall be determined as to whether the stockholders of the divided corporation, etc. have disposed of less than 1/2 of the total stocks, etc. received through the division, or if the stocks, etc. received through the division are disposed of between the relevant stockholders, etc., it shall not

Congress RESALS

In applying Article 82-4 (6) 2 of the Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 23589, Feb. 2, 2012), whether a person falls under Article 80-2 (1) 1 (a) of the Enforcement Decree of the same Act shall be determined as whether the stockholders of a divided corporation, etc. under Article 82-4 (8) of the Enforcement Decree of the same Act dispose of less than 1/2 of the total stocks, etc. received through the division; however, the disposal between the stocks, etc. received through the division by the relevant stockholders, etc. under Article 80-2 (5) of

Related statutes

Article 116 of the Corporate Tax Act

Main text

1. Facts and summary of the questioning

B/L Factual relations

○ A Juristic Person, after being divided into persons in April 2012, shall be deemed to exist until now with B, a corporation established through division.

○ The status of stockholding and disposal of B Corporation shall be as follows: