종합소득세부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. The Plaintiff provided management consulting services to C, the representative of the Hong Kong corporations B Co. Ltd., and received from C, on five occasions from November 28, 2008, to December 23, 2009, USD 2,500,00 ($ 3,179,487,000 in original conversion conversion amount, KRW 1,421,394,000 in the amount belonging to the year 2008, and KRW 1,758,09,00 in the amount belonging to the year 209, as shown in the following table: < Amended by Presidential Decree No. 20009, Nov. 28, 2008; Presidential Decree No. 2000, Feb. 1, 2008>
On November 23, 2008, 200, 500,000, 740,312,000 on November 23, 2008, 200, 500,000, 680,082,000 small 1,000,000, 1421,394,000 on December 15, 2009 (the first gold source of this case), 80,84,000 on December 15, 200, 930,84,000,000 on 930,84,000,000 on 20,35,005,235,5384,50,000 on December 21, 2009; and
B. In filing the final tax return on global income tax for the year 2008, the Plaintiff reported the instant KRW 1, and the instant KRW 2, upon filing the final tax return on global income tax for the year 2009, the Plaintiff reported the instant KRW 2, except for each income amount
C. From August 30, 2011 to October 22, 2011, the Defendant conducted a tax investigation on the Plaintiff (hereinafter “instant tax investigation”).
As a result, on December 1, 2011, the Defendant confirmed that the Plaintiff omitted the amount of global income tax for the year 2008 and 2009, and notified the Plaintiff of the total amount of global income tax for the year 2008 as KRW 702,568,795, and the total amount of global income tax for the year 2009 as KRW 854,68,431 without deducting necessary expenses.
Since then, the Defendant revised the global income tax for the year 2008 and 2009, and notified the Plaintiff of the total amount of global income tax for the year 2008 as KRW 904,883,578, and the total amount of global income tax for the year 2009 as KRW 873,257,086.
E. The plaintiff is dissatisfied with this and deducts necessary expenses.