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(영문) 서울행정법원 2015.10.02 2015구합51224

법인세 부과처분 등 취소

Text

1. The disposition of imposition and the defendant in attached Form 1 committed by the Head of Central Tax Office on the New World Co., Ltd.

Reasons

1. Details of the disposition;

A. On May 1, 2010, the business division of “bekia” operated by a shipbuilding hotel (hereinafter “SB”) was acquired on May 1, 2010, and the company changed its trade name on January 4, 2012 to the New World EsBE (hereinafter “SBE”).

B. Embent sells bret and Embret, which is operated by the Plaintiffs, affiliates, and sales of brecons, skins, and other food drinks within the new world department stores, and at least 80% of the sales are arising from transactions with the Plaintiff New World Co., Ltd. (hereinafter “Plaintiff New World”) and the Plaintiff Embret (hereinafter “Plaintiff Embte”).

C. The Plaintiff New World reduced 22% of the sales commission rate from August 8, 2009 to 15% from 2009, when the supplier sells food beverages to the brand called “Skknatian headquarters” (the shipbuilding hotel up to April 2010) and the specific purchase transaction (the transaction in which the supplier sells its goods to the store of large scale retailers and pays a certain portion of the sales commission to large-scale retailers in the form of sales commission).

In addition, the sales commission rate of 15% from March 2009 and September 2009 was applied respectively to the new world department store Busan department store and the new world department store Gangnam department store.

The changes in the sales commission rate applied to the store by the plaintiffs in Eba in the brand called "Yabab" and selling Blubbbbbb breabb in a specific purchase transaction with Ebaba, are as follows:

(Plaintiff Emart was divided from the Plaintiff New World on May 1, 201). 2005 to 2006 2007 2007 2009 to 2010.3 to 2011.3 to 201.2.5 to 22.5% from the New World on February 25, 2011 to September 25, 2012 22.5% 22.7% 22.8% 20.5% from the 20.5% from the 20.5% from the 2011 to the 20.5% from the 20.5% from the 20.5% from the 20.5% from the 20

E. The plaintiffs are E.E. E. E. E. E. E. E.I.