The costs of appeal are assessed against the defendant.

Article 10 of the former Restriction of Special Taxation Act (Amended by Act No. 10406, Dec. 27, 2010; hereinafter the same shall apply) 10

Paragraph (1) of this Article shall apply to a national who has a research and human resources development expenses for each taxable year.

The former Enforcement Decree of the Restriction of Special Taxation Act provides that corporate tax shall be deducted.

Attached Table 6 of Article 9(2) of the former Act and its tax characteristics (amended by Presidential Decree No. 21307 of Feb. 4, 2009)

Article 8 (1) of the Enforcement Decree of the Restrictions Act (Amended by Presidential Decree No. 23590, Feb. 2, 2012)

Table 6 is one of the research and human resources development expenses subject to such tax credit as above, by Ordinance of the Ministry of Strategy and Finance.

Employees working for a department exclusively in charge determined by Ordinance of the Ministry of Strategy and Finance (hereinafter referred to as "exclusive department").

The personnel expenses of those who are employed are ‘the personnel expenses'.

The lower court, based on its adopted evidence, found the Plaintiff’s work at a research institute affiliated with its exclusive department.

of this case paid to the Institute in 2007 to 2010

Recognition as personnel expenses subject to tax credit for research and human resources development expenses under Article 10(1) of the Special Act on Restriction on Taxation

The director of the Daejeon District Tax Office received corporate tax equivalent thereto, and the director of the Daejeon District Tax Office otherwise received.

It seems that retirement pension contributions do not constitute personnel expenses subject to tax credit for research and human resources development expenses.

H. The fact that on November 26, 2013, the Plaintiff corrected and notified corporate tax for the business year from 2007 to 2010 respectively to the Plaintiff.

Recognizing the facts.

Next, the lower court: (1) on the basis of the final and conclusive retirement pension plan, the taxable year and period by the Plaintiff

The retirement pension premium of this case actually paid according to the research institute's continuous service for each regular employee is the case.

shall be recognized as the cost of the expenditure year, and the amount equivalent to the above insurance premium shall be paid to each researcher.

(2) The retirement pension premium in this case can be seen as a final attribution.

agency may directly respond to the research and human resources development for the pertinent taxable year and actually disbursed by each researcher.

It is not reasonable to estimate the cost reasonably for calculating the profit and loss for a reasonable period of time.

The retirement pension of this case is different from the retirement pension of this case in light of its nature.

Insurance premiums shall be subject to tax credit for research and human resources development expenses under Article 10 (1) of the former Restriction of Special Taxation Act.

The purport that the instant disposition taken on a different premise constitutes personnel expenses is unlawful.

The judgment was determined as follows.

Examining the reasoning of the lower judgment in light of the relevant legal principles and records, the lower court’s determination is justifiable.

In light of the above, the research and the person under Article 10(1) of the former Restriction of Special Taxation Act, as otherwise alleged in the grounds of appeal.

There was no error by misapprehending the legal principles concerning the scope of personnel expenses eligible for the tax credit for power development costs.

Therefore, the appeal is dismissed, and the costs of appeal are assessed against the losing party. It is decided by all participating Justices.

It is decided as per Disposition by the assent of all participating Justices.