지급수수료 손금불산입 및 업무무관 가지급금 지급이자 손금불산입[일부국패]
Seoul High Court-2015-Nu-6933 (Law No. 21, 2016)
Non-deductible of the payment fee, non-deductible of the interest paid in no business
Even if a corporation distributes profits from remodeling projects to shareholders in the manner of capital reduction, it is not allowed to include the fees in the corporation's deductible expenses if the nature of the fees is the expenses to be borne by the shareholders remaining as a sole shareholder, and the representative's disposition is legitimate.
Article 19 (Scope of Losses)
Article 19 of the Enforcement Decree of the Corporate Tax Act (Scope of Losses)
Supreme Court Decision 2016Du56981 Decided revocation of Disposition of Corporate Tax Imposition
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○ Head of tax office
December 23, 2017
All appeals are dismissed.
The costs of appeal between the Plaintiff and the Defendant Seoul Regional Tax Office are assessed against the Plaintiff and the Defendant
The parts arising between Samsung Head of Samsung Tax Office shall be borne by each party.
All of the records of this case and the judgment of the court below and the grounds of appeal were examined. However, the grounds of appeal on the grounds of appeal do not include the grounds provided in each subparagraph of Article 4(1) of the Act on Special Cases Concerning the Procedure for Appeal of Supreme Court, or are without merit. It is so decided as per Disposition by the assent of all participating