부가가치세부과처분취소 등
1. Of the judgment of the first instance court, the part against the plaintiffs which is revoked below shall be revoked.
Defendant on August 12, 2013, to Plaintiff A.
1. Details of the disposition;
A. 40% of the plaintiffs in relation to the specially related parties respectively
A. Plaintiff A is a limited liability company (hereinafter “instant company”) holding Plaintiff B’s external third village and 30% (Plaintiff B) shares.
) On January 31, 2008, PSIE (hereinafter “SSIE”)
(E) From Seocho-gu Seoul Metropolitan Government D (hereinafter “E”) and F’s land located outside of 1,000 square meters (hereinafter “instant site”)
A) On the ground and on the ground, approximately KRW 4,929.19 square meters of the total floor area of the building of the five-story above ground, which was scheduled to be constructed (hereinafter “instant building”). The instant building site is combined with the instant building site, and “the instant real estate” is deemed to be “the instant real estate.”
(B) The instant company concluded a real estate sales contract that takes over KRW 36,500,000 on March 26, 2009. However, the instant company paid KRW 18,250,000 as the contract deposit and intermediate payment, and did not complete the liquidation of the balance, while it did not pay KRW 18,250,000 on March 26, 2009.
2) As to the instant real estate, the sales price was KRW 21,730,000,000 and was transferred to the buyer’s status as the purchaser (hereinafter “transfer of this case”).
(3) On July 1, 2011, the instant company notified the instant company of the correction of KRW 1,025,178,940 for the first term portion of value-added tax for the year 2009, on the ground that the instant transfer constitutes an oligopolistic shareholder, and thus, the instant company did not pay the instant transfer after its closure and liquidation on June 15, 2009, deeming that the Plaintiffs, who are investors of the instant company, constitute oligopolistic shareholder, were designated as the secondary taxpayer and the value-added tax 410,071,570 (including additional tax) and increased 125,481,820 (Plaintiff A, Plaintiff A, Plaintiff A, and Plaintiff A, etc.) on August 12, 2013, deeming that the instant transfer constituted an oligopolistic shareholder.