채권 저가 매각이 사기 기타 부정한 행위에 해당하여 장기 부과제척기간이 적용되는지 여부[국승]
Seoul High Court-2015-Nu-47012 (No. 13, 2016)
Whether a long-term exclusion period for taxation is applied because the sale of low price of bonds falls under fraudulent or other unlawful acts
In order to manipulate the rate of return on the fund, the low-price sale of the claim corresponding to the act of breach of trust constitutes fraud or other unlawful act, and the period of exclusion for ten years is applied.
Article 26-2 of the National Tax Basic Act
2016Du32725 Revocation of Disposition of Imposing Corporate Tax
AAAAAA Limited Liability Company
BB Director of the Tax Office
Seoul High Court Decision 2015Nu47012 Decided January 13, 2016
April 29, 2016
1. The appeal is dismissed.
2. The costs of appeal are assessed against the Defendant.
All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the assertion on the grounds of appeal by the appellant constitutes Article 4 of the Act on Special Cases Concerning the Procedure for Appeal and therefore, the appeal is dismissed under Article 5 of the above Act. It is so decided as per Disposition by