법인세부과처분취소
1. All of the plaintiff's claims are dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. According to Article 18-3 of the former Corporate Tax Act (amended by Act No. 8831, Dec. 31, 2007; hereinafter “former Corporate Tax Act”) at the time of reporting the tax base and amount of corporate tax for the business year 2006 and the business year 2007 as a corporation engaged in financial business, the Plaintiff excluded each dividend amount of KRW 12,874,097,623, and KRW 19,385,069,512 in the business year 2006 from the calculation of the amount of gross income, and excluded the interest on the deposit in Korean currency from the “interest on the loan” which is deducted at the time of calculating the amount of income dividends from the gross income.
(Unit) Classification of KRW 3,433,434, 134, 547, 147, 144, 123, 596, 5947, 577,57,731, 139, 184, 916, 1637, 95, 366, 734, 777,068, 51, 650, 3168, 312, 438, 169, 347, 247, 1245, 248, 59, 59, 2648, 167, 247, 1385, 648, 257, 2685, 3685, 267, 3685, 2685, 297, 2678, 2685, 263867, 2675
B. The director of the Seoul Regional Tax Office: (a) deemed the interest paid on the said table as the issue financial bonds; (b) the interest on repurchase agreement; (c) the interest on a trust account; (d) the interest on sales discount agreement; and (e) the sales discount agreement; and (e) other interest paid (hereinafter “interest on the instant issue”); and (c) the Korean won currency money interest (hereinafter “interest on the instant issue”); and (d) the amount of KRW 1,215,650,098 as the interest on a loan deducted at the time of calculating the amount of
C. Accordingly, the Defendant, on March 5, 2012, issued a revised notice of the amount of corporate tax 486,693,900 and April 6, 2012 to the Plaintiff on March 5, 2012, by including the interest on the instant interest on the loan, which is deducted when calculating the amount of the interest on import dividends in gross income, in calculating the amount of the interest on the loan that is deducted from gross income, respectively.
The business year of 2006 and 2007