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(영문) 서울고등법원 2017.05.31 2016누39766

법인세부과처분취소

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1. Revocation of the first instance judgment.

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

Reasons

1. Presumed factual basis

A. The Plaintiff is an insurance company established on June 1, 1989 for the purpose of life insurance business and life insurance business.

B. From 2005, the Plaintiff entered into a consignment development service contract with an external company and promoted the development of a computer system for contract management, financial and sales support.

On October 2005 to June 2006: A system replacement project (GPAR hereinafter referred to as "GPAR") will take place on August 2006: (a) from August 2006 to August 2008: based on GPAR, in consideration of the characteristics of the business environment and transaction structure of the domestic insurance company, the Ministry of Strategy and Finance will select a system replacement project (KPAR ; hereinafter referred to as "KPAR"), separate from the GPAR ; (b) select a system replacement project (hereinafter referred to as "KPAR "); (c) select a system replacement project (hereinafter referred to as "NPAR 2"); (d) select a system replacement project and a system replacement project (hereinafter referred to as "GPAR 2"); (d) select a company that will carry out the order production and construction of the above package 2; (e) select a company that will carry out the installation of a new system; (e) select a system replacement project; (e) select a new system replacement project-20-20-20-20-20-20-20-20-20-

C. The Plaintiff’s development of the NFS program on December 17, 2007, and Samsung SPC Co., Ltd. (hereinafter “SPC”) and the development of the PSR program on July 23, 2008.