연구및인력개발비는 수탁업체의 재위탁 여부 및 재수탁업체의 연구전담부서 보유 여부에 관계없이 세액공제대상임 [국패]
Seoul Administrative Court 2012Guhap34440 ( October 14, 2013)
Research and human resources development expenses are subject to tax credit regardless of whether the trustee is re-entrusted, and whether the trustee is holding a research department of the re-entrusted company
Research and human resources development expenses paid by entrusting research services to an enterprise with a department in exclusive charge of research shall be eligible for tax credit regardless of whether it is re-entrusted by an entrusted enterprise and whether it is owned by a department in exclusive charge of
2013Nu20242 Revocation of revocation of a request for corporate tax revision
AA card corporation
BB Director of the Tax Office
Seoul Administrative Court Decision 2012Guhap34440 decided June 14, 2013
March 19, 2014
April 30, 2014
1. The defendant's appeal is dismissed.
2. The costs of appeal shall be borne by the Defendant.
1. Purport of claim
The defendant's rejection disposition against the plaintiff on September 28, 2012 against the plaintiff is revoked.
2. Purport of appeal
The judgment of the first instance is revoked. The plaintiff's claim is dismissed.
1. cite the judgment of the first instance;
The reasoning of this court's judgment is the same as that of the court of first instance, and thus, it is cited in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of the Civil Procedure
2. Conclusion
The judgment of the first instance is justifiable. The defendant's appeal is dismissed.