종합소득세부과처분취소
1. The Defendant’s global income tax amounting to KRW 25,331,130 (including additional taxes) for the Plaintiff on March 11, 2015 and reverted to the Plaintiff in 2008.
1. Details of the disposition;
A. The Plaintiff is a corporation of the Republic of Indonesia (hereinafter “Indonesia”) that produces clothing products around 1996, B and B.
A) establish B’s largest shareholder (95 per cent equity interest) up to now.
(C) A representative director is working as the representative director, and the Indonesia Corporation C and hereinafter referred to as "C") is established and operated in 201.
On the other hand, around April 2005, the Plaintiff established D Co., Ltd. (hereinafter referred to as “D”) which is a domestic corporation and has been working as its largest shareholder (80% shares) up to now, and is working as its representative director.
B. From 2007 to 2013, the Plaintiff reported and paid income tax in Indonesia on the earned income that he received from B.
On the other hand, D withheld and paid labor income tax from 2007 to 2012 when paying wages to the Plaintiff, and the Plaintiff reported and paid comprehensive income tax on the earned income and dividend income paid from D in 2013.
C. The Defendant deemed the Plaintiff as a resident of Korea from 2007 to 2013 and deducted the amount of tax paid by the Plaintiff in Indonesia after aggregating the Plaintiff’s wage and salary income and dividend income accrued in Korea and the Plaintiff’s wage and salary income accrued in Indonesia during that period. On March 11, 2015, the Plaintiff included the global income tax of 25,331,130 won (including additional taxes), global income tax of 207, global income tax of 2008, global income tax of 41,364,290 (including additional taxes), global income tax of 113,883,580 won (including additional taxes), global income tax of 209, global income tax of 128,92,230 won (including additional taxes), global income tax of 201, global income tax of 70,828,270 won (including additional taxes), global income tax of 2012, global income tax of 61,3437,437
(hereinafter referred to as "each disposition of this case"). 【No dispute exists concerning each disposition of this case, evidence Nos. 1, 3, 5, 6, 7, 25, 51, 52.