대가 관계가 수반되어야만 순환거래에 참여하게 된다고 보기는 어려움[국승]
Seoul High Court 2012Nu15977 (2013.02.08)
Cho High Court Decision 2010Du0625 ( October 10, 2011)
It is difficult to deem that the consideration relationship is accompanied by but is involved in circular transactions.
IT companies appear to have used a method of going through only a tax invoice of companies participating in circular transactions without real in order to eliminate external forms. However, in the case of such circular transactions, it is difficult to see that the relevant companies are participating in circular transactions, although monetary prices are necessarily involved.
2013du5692 Revocation of disposition of imposing corporate tax, etc.
AAAA
Head of Geumcheon Tax Office
Seoul High Court Decision 2012Nu15977 Decided February 8, 2013
The appeal is dismissed.
The costs of appeal are assessed against the Plaintiff.
In accordance with Article 8(2) of the Administrative Litigation Act, Article 429 of the Civil Procedure Act, and Article 5 of the Act on Special Cases Concerning the Procedure of Final Appeal, the appeal is decided as per Disposition by the assent of all participating Justices.
Reference materials.
If the grounds for final appeal are not included in the grounds of appeal that make it appropriate for the court of final appeal to become a legal trial, such as matters concerning significant violation of Acts and subordinate statutes, etc., the system of final appeal will not continue to proceed with the deliberation on the merits of the grounds for final appeal, but will not proceed with the deliberation on the merits of the grounds for final