(심리불속행) 특수관계자인 원고에게 부당행위계산부인 규정을 적용하여 종합소득세를 과세할 수 있음[국승]
Seoul High Court-2014-Nu-62892 ( dated 17, 2015)
(P) The Plaintiff, a person with a special relationship, can be imposed with the comprehensive income tax by applying the provision regarding wrongful calculation.
(C) If it is deemed that an act of a domestic corporation or the calculation of the income amount of a domestic corporation has unjustly reduced the tax burden on the income of the corporation in transactions with a specially related person, the summary may calculate the income amount of the corporation for each business year, regardless of the amount of the act or the calculation
2015du48921 global income and revocation of disposition
○ ○
○ Head of tax office
Seoul High Court Decision 2014Nu62892 Decided July 17, 2015
September 17, 2015
The appeal is dismissed.
The costs of appeal are assessed against the Plaintiff.
As the petition of appeal does not contain any statement in the grounds of appeal and did not submit the grounds of appeal within the statutory period, it is so decided as per Disposition by the assent of all participating Justices, pursuant to Article 8(2) of the Administrative Litigation Act, Article 429 of the Civil Procedure Act, and Article 5 of the
September 17, 2015