Seoul High Court-2017-Nu-53202 ( December 20, 2017)

Cho Jae-2015-Seoul Office-4836 ( December 30, 2015)

Title trust may be deemed to have a purpose other than the purpose of tax avoidance, and there is no tax avoidance.

In order to comply with the duty not to engage in the competitive business, title trust was held in order to observe the duty not to engage in the competitive business, and there is no amount of dividend paid, etc.

Article 45-2 of the former Inheritance Tax and Gift Tax Act [Presumption of Donation of Title Trust Property]

2018Du32477 Revocation of Disposition of Imposition of Gift Tax

LGR foreign1

J Head of J Tax Office

on April 26, 2018

The appeal is dismissed.

The costs of appeal are assessed against the defendant.

All of the judgment below and the appellate brief examined the records of this case, but the appellant's grounds of appeal are not included in the grounds provided by each subparagraph of Article 4 (1) of the Act on Special Cases Concerning the Procedure of Appeal, or are recognized to be groundless. Thus, the appeal is dismissed pursuant to Article 5 of the same Act. It is so decided as per Disposition by the assent of