법인세부과처분취소
1. The defendant's appeal is dismissed.
2. The costs of appeal shall be borne by the Defendant.
Purport of claim and appeal
1..
1. The reasons why this part of the disposition is stated by the court are as follows, and the corresponding part of the judgment of the court of first instance (from No. 2 to No. 31) is the same as the corresponding part of the judgment of the court of first instance, except for the dismissal or addition of a part of the judgment of the court of first instance as follows. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article
Part 4 of the second reason is "Sap Kong" to the effect that "the plaintiff has invested 100% in Hong Kong on November 21, 2006".
The second and second "Ltd." added "(hereinafter referred to as the "instant company") to "Lt.(hereinafter referred to as the "instant company") and both "this overseas subsidiary" and "the above subsidiary" in the 6th and the 10th and 11th in all "the instant company" are "the instant company."
Part 7 of Paragraph 2, for the second reason, the term "international tax law" shall be read as "former international tax law".
Part 10 of the second ground "207 business year" shall be added to "(round October 2007)" after the second ground.
Part 3 of the Second Class "International Article 1, 2, 3, and 5 of the former International Article 10 shall be applied to "A, 2, 3, and 5", and Part 10 shall be applied to "A, 1, 2, 3, 27, and 30."
2. The details of the relevant Acts and subordinate statutes are as shown in attached statutes;
3. Whether the instant disposition is lawful - This Court’s reasoning concerning this part of the computation of the arm’s length price according to the National Tax Service model is as follows, and the corresponding part of the first instance judgment (from No. 3 to No. 14 and No. 5 to No. 30), other than to dismiss or add part of the first instance judgment, is the same as the corresponding part of the first instance judgment (from No. 13 to No. 14, No. 14 and No. 5 to No. 30). As such, it shall be cited pursuant to Article 8(2) of the Administrative Litigation
Article 13 of the former International Tax Adjustment Act (amended by Presidential Decree No. 21299 of Feb. 4, 2009), while Article 9-10 of the former Enforcement Decree of the Adjustment of International Taxes Act (amended by Presidential Decree No. 21299 of Feb. 4, 2009) is the former International Tax Adjustment Act.