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(영문) 서울행정법원 2014.04.24 2013구합5487

종합소득세등부과처분취소

Text

1. The plaintiff's primary and conjunctive claims are all dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Reasons

1. Details of the disposition;

A. The U.S. R&C International company (hereinafter “R&C”) entered into a contract with R&C to sell a special power plant manufactured by R&C in Korea (hereinafter “R&C”) on behalf of the Plaintiff on August 9, 2005 (hereinafter “R&C”) with R&C on behalf of the R&C, and entered into the following contracts with R&C to sell a special power plant manufactured by R&C in Korea (hereinafter “R&C”).

This Agreement was concluded between B and R&C on August 9, 2005.

The effective date of this Agreement shall be August 9, 2005 and shall continue until December 31, 2010.

The preceding sentence (A) R&C is engaged in the business of supplying goods from Korean electricity, equipment, and machinery parts to various industries.

(B) B provides consulting services, including, but not limited to, marketing, contact with the potential and present customers of R&C and not limited to, marketing, contact, and initial notification.

Recognizing that value-based considerations have been fully considered, R&C and B agree as follows:

Dried cases

1. B’s obligations to R&C (a) shall provide consulting services, including, but not limited to, marketing, contact with and initial notice to, the potential and current customers of R&C in Korea.

(b) B shall provide to R&C with customer contact information and, if specific requests are made available, the contact information of the customer.

2. The R&C obligations to B (a) R&C shall pay to B 80 per cent of the net proceeds accruing from the sales generated from each project.

(b) Payment shall be made at the time of the completion and completion of each project.

(c) Net proceeds are defined as the total proceeds derived from costs incurred to R&C in the United States.

(d) The project is defined as one or more sales of goods to one customer.

B. The Plaintiff has since the R&C since 2006 pursuant to the instant contract.