특수관계법인에게 저작권수입의 무상 양도는 부당행위계산에 해당함[국승]
Seoul High Court-2018-Nu-51760 ( October 11, 2019)
Cho-2017-China-502 (2017.08)
Transfer of copyright income to a related corporation without compensation is subject to wrongful calculation.
It is legitimate to impose income tax, etc. on the act that the plaintiff who is a substantial copyright holder transfers the copyright to a related corporation without compensation in accordance with the denial of wrongful calculation.
Article 41 of the Income Tax Act
Revocation of Disposition Imposing Corporate Tax
Note 00 1
00. Head of tax office
on October 16, 2019
1. All appeals are dismissed.
2. The costs of appeal are assessed against the plaintiffs.
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 appellant's grounds of appeal fall under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal and therefore, all of the appeals are dismissed pursuant to Article 5 of the above Act. It is so decided as per Disposition by