증여세부과처분취소
1.(a)
On October 1, 2013, the head of Seocho District Tax Office (including additional taxes) imposed on the Plaintiff A on the gift tax of KRW 958,964,930 (including additional taxes).
1. Details of the disposition;
A. On September 25, 2012, the Plaintiff’s father C entered into a four immediate pension insurance contract with Samsung Life Insurance Co., Ltd. with the amount of KRW 20 billion as follows: (a) 10 years; (b) the starting date of the pension; (c) 25 October 2012; and (d) the amount of lump-sum payment insurance premium: (c) 4 immediate pension insurance with the amount of KRW 5 billion; and (d) paid the total insurance premium.
- Receipt of monthly pension in the name of the product type insurance premium (temporary payment) to be received each month of the monthly pension insurance premium for the product type (a short-name pension premium) 1.3 (Undistribution) D 10-year pension insurance for 10 years - Receipt of monthly pension in the name of the product 13,938,532 KRW 13,938,532 KRW 13,938,532 KRW 13,938,532 KRW 13,938,532 KRW 5,932 KRW 13,938,532 KRW 13,932 KRW KRW 5,932 KRW 30,532 KRW 4 insurance in the name of the product .
B. On October 17, 2012, C drafted a gift contract under the following subparagraphs with respect to each gift of insurance 1, 2, and 3, and 4 to the Plaintiff A, respectively.
1. Title 1) Item 2: Insurance premium for inheritance-type pension insurance (10-year pension insurance) (10-year pension insurance): 5 billion won (10-year pension payment) monthly (10-year pension payment) (4) monthly (13,938,532 (167,262,384 won a year) monthly amount: 13,938,532 (167,262,384 won a year) monthly amount: The right to receive monthly pension (10-year pension) and the right to receive insurance premium (10-year pension insurance premium) at the maturity of the insurance contract (10-year pension premium) shall be the donation method: (6) the donation method shall be changed from policyholders, beneficiaries (interest), and beneficiaries specified in the insurance contract (10-year pension policy) to C to the Plaintiffs.
C. Accordingly, on October 19, 2012, C changed the policyholders, pension beneficiaries, and maturity beneficiaries of insurance Nos. 1 and 2 from October 19, 2012 to Plaintiff A, insurance No. 3 and 4 from policyholders, pension beneficiaries, and maturity beneficiaries to Plaintiff B respectively.
Plaintiff
A shall be effective as of 2013.