OTC와 ELW거래는 회피된 조세가 없으므로 실질과세원칙을 적용할 수 없음[국패]
Seoul Administrative Court-2014-Gu Partnership-7012 ( October 07, 2015)
Cho High-2014-Seoul Government-036 (Law No. 23, 2014)
al n7f l7f x7f lx7f l x76 lg x76 lg x76 lg lg x76 lg x76 lg lg x76 lg lg x7f lg x7f lg x7f lg x7f lg x7f lg x7f lg x7f lg x76 lg x76 lg x76 lg x7f x7f lg x7f lg x7f lg x7f l l
(In other words, the entire business year only differs from the year to which the profit and loss are attributed, and the principal tax to be additionally paid is not a problem, and the substance over form principle cannot be applied as it is a matter of reporting and additional tax in a post facto aspect.
Article 4 of the Corporate Tax Act
2015Nu63465 Revocation of Disposition of Corporate Tax Imposition
OOOOOOcyd
○ Head of tax office
Seoul Administrative Court Decision 2014Guhap70112 Decided October 07, 2015
2016.08.26
1. The defendant's appeal is dismissed.
2. The costs of appeal shall be borne by the Defendant.
1. Quotation of the reasons for the judgment of the first instance;
The reason for this decision is the same as the reason for the judgment of the court of first instance, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the
2. Conclusion
Therefore, the plaintiff's claim is justified, and the judgment of the court of first instance is just, and the defendant's appeal is dismissed as it is without merit. It is so decided as per Disposition.