법인세등부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. The Plaintiff (only “Plaintiff,” regardless of whether it was established before or after the division, was divided from the golf-based capital brokerage, which was established on January 26, 2015, is a company with the purpose of manufacturing, selling, and services for golf products, golf practice ranges, golf course businesses, screen golf business, etc., and operates a department in exclusive charge of research and development on manufacture, such as screen golf, 207.
3. On 28. 28. The head of the Korea Industrial Technology Association, an incorporated association, recognized a research institute affiliated with a company that is a second company affiliated with the company (hereinafter “instant research institute”) as a research institute affiliated with a company as prescribed by the Technology
B. The Plaintiff disbursed the retirement pension premium for the employees of the instant research institute until the business year 2007 through 2010 to KRW 44,431,867 in the business year 207, KRW 88,145,00 in the business year 2008, KRW 203,089, KRW 626 in the business year 2009, KRW 484,802,063 in the business year 209, and KRW 820,468,556 in the aggregate.
(hereinafter “Retirement Pension Contribution of this case”). C.
The Plaintiff’s “research and human resources development expenses omitted at the time of filing a corporate tax return for the business year 2004 through 2006” and “retirement pension premium” with the head of Seo-gu Daejeon District Tax Office on December 9, 201, shall be deemed to be the “tax credit under the Restriction of Special Taxation Act” under Article 10(1) of the former Restriction of Special Taxation Act (amended by Act No. 9272, Dec. 26, 2008; Act No. 9921, Jan. 1, 2010; Act No. 10406, Dec. 27, 2010; Act No. 11133, Dec. 31, 2011; hereinafter collectively referred to as the “former Act”).
In accordance with the target research and human resources development expenses, 319,261,426 won of corporate tax for the business year 2007, 356,872,797 won of corporate tax for the business year 2008, 747,793, 173 won of corporate tax for the business year 2009, and 766,74,277 won of corporate tax for the business year 2010, 2,190,671,673 won of corporate tax for the business year 2007.