법인세부과처분취소
1. Revocation of a judgment of the first instance;
2. The Defendant’s corporate tax for the year of the death of 2006, March 5, 2012, against the Plaintiff 486,693.
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, 577,577,731, 139, 184, 916, 1637, 95, 366, 734,77,068,51,51,650 repurchase agreement and 312,438,438,169, 347, 247, 245, 138, 657, 247, 659, 648, 657, 658, 648, 658, 267, 6537, 2685, 278, 2685, 2965, 278, 2685, 26368, 26865
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 currency deposit interest and KRW 1,215,650,098 as the interest on loans deducted at the time of calculating the amount of non-Inclusion in gross income, and notified the Defendant of the taxation data
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 2012, 206, including the interest on the instant interest on the loan that is deducted when calculating the amount of non-inclusion in the gross income for import dividends, and re-calculated the amount of non-inclusion in the gross income for import dividends to the Plaintiff.
The business year of 2006 and 2007