법인세 징수 및 부과처분 취소
1. The judgment of the court of first instance is modified as follows.
The defendant's business year of December 2, 2011 against the plaintiff on December 2, 2013.
1. The reasoning for the court’s explanation on this part is as follows, except for the corresponding part among the judgment of the court of first instance, and is the same as the part of the “1. Ground for Disposition” stated in 2-3 pages of the judgment of the court of first instance. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.
The following shall be added to the right side of two parts of the reasons for the second judgment “A.”:
O :
E.
F. Five funds, including F., were established at around 200 as a U.S. patent management specialized company that processes the management of the patent owned by them with delegation from the U.S. Funds, and the two pages below the “E.” (hereinafter referred to as “E”) and add “F.” to the right side of the “F.” (hereinafter referred to as “F.”). The following is added to the two pages “F...” The two pages at the end, “F.......” Of the instant royalties, the patent fees registered in the Republic of Korea are 242,375,05 won among the service fees for the business year 2011 and 117,284,842 won among the service fees for the business year 2012, and the remainder of the service fees are non-registered in the Republic of Korea.
3. The term “before the amendment” means “before the amendment; hereinafter “former Corporate Tax Act”).” The 3rd 11st 3rd 1st 3rd 1st 3rd 1st 1st 2st 2nd 3rd 2nd 3rd 2nd 3rd 3rd 3rd 3rd 8th 3rd 3rd 3rd 3rd 8th 3rd 2nd 3rd 3rd 4rd 2nd 3rd 3rd 2nd 4rd 4th 2nd 4th 3rd 4th 4th 2nd 4th 4th 2nd 3rd 3rd 3rd 4th 2nd 3rd 3rd 3rd 4th 3rd 4th 2nd 3rd 4th 3rd 4th 3rd 4th 4th 3rd 4th 3rd 200.
3. This is based on the substance over form principle under the Framework Act on National Taxes.