연구개발비 세액공제 대상인지 여부[국패]
Seoul Administrative Court 2012Guhap32949 (2013.05.03)
2010u2509
Whether research and development expenses are subject to tax credit
If research and development expenses are paid to an entrusted enterprise that has an exclusive department in charge of research and development in the legislative intent and the interpretation of the language and text, it is eligible for tax credit regardless of whether it has a exclusive department
Attached Table 6 of the Restriction of Special Taxation Act
2013Nu16199 Revocation of Disposition of Corporate Tax Imposition
AA Securities Corporation
Head of Yeongdeungpo Tax Office
Seoul Administrative Court Decision 2012Guhap32949 decided May 3, 2013
February 27, 2014
April 24, 2014
1. The defendant's appeal is dismissed.
2. The costs of appeal shall be borne by the Defendant.
1. Purport of claim
The defendant's imposition of the corporate tax for the business year 2008 against the plaintiff on April 2, 2010 and the corporate tax for the business year 2009 is revoked.
2. Purport of appeal
The judgment of the first instance is revoked. The plaintiff's claim is dismissed.
The reasoning of the judgment of the first instance is reasonable, and thus, it is accepted on the ground of this judgment pursuant to Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act. (In full view of each of the statements in the evidence Nos. 7 and 8, it is difficult to accept the Defendant’s assertion, and the instant disposition that excludes the research and development expenses re-entrusted to a re-entrusted company that the trustee
The defendant's appeal is dismissed for lack of reason.