연봉제 전환을 이유로 임원 퇴직금 중간정산한 경우 실제 연봉제 전환이 없어서 퇴직금 상당액을 손금불산입함[국승]
Seoul High Court-2015-Nu-50537 ( October 27, 2015)
In case of interim settlement of retirement allowances for officers on the grounds of conversion of the annual salary system, the actual amount of retirement allowances is not included in deductible expenses as there is no conversion.
Where an interim settlement of retirement allowances for officers is made on the grounds of the conversion of the annual salary system, a disposition to pay an amount equivalent to retirement allowances as deductible expenses is legitimate because the actual conversion of the annual salary system
Article 44 of the Enforcement Decree of Corporate Tax Act
2016Du58533 Revocation of Disposition of Corporate Tax Imposition
AAAAAA Corporation
BB Director of the Tax Office
Seoul High Court Decision 2015Nu50537 Decided October 27, 2015
March 10, 2016
1. The appeal is dismissed.
2. The costs of appeal are assessed against the Defendant.
All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the assertion on the grounds of appeal by the appellant constitutes Article 4 of the Act on Special Cases Concerning the Procedure for Appeal and therefore, the appeal is dismissed under Article 5 of the above Act. It is so decided as per Disposition by