Seoul High Court 2013Nu8242 (Law No. 12, 2014)

Seocho 2012west 2539 ( October 31, 2014)

It is reasonable to view that advisory services have been performed independently by utilizing professional knowledge continuously and repeatedly, and therefore constitutes business income.

" insofar as advisory services provided by the plaintiff in relation to the management and tax management have the nature of counseling, supervision, guidance fees, and advisory fees, the defendant's disposition of this case which applied the expense rate of personal services corresponding thereto cannot be deemed unlawful" (the contents of the judgment)

Article 19 of the Income Tax Act

2014du5187 Global income and revocation of disposition

LAA

Samsung Head of Samsung Tax Office

Seoul High Court Decision 2013Nu8242 Decided February 12, 2014

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, 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 for Appeal. Accordingly, the appeal is dismissed pursuant to Article 5 of the same Act and the costs of appeal are assessed against the losing party. It is so decided