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(영문) 서울행정법원 2018.11.23 2018구합61307
부가가치세등부과처분취소
Text

1. Of the instant lawsuit, the Defendant’s additional tax amounting to KRW 2,282,270, which was imposed on the Plaintiff on January 1, 2017.

Reasons

Details of the disposition

The plaintiff is a company engaged in construction business, real estate sales agency business, etc., and B is a company director and a shareholder who owns 100% shares as 10% shares, and controls the conclusion of the contract, financing management, and

From August 17, 2016 to November 30, 2016, the Defendant: (a) as a result of conducting an integrated investigation into corporate tax and other corporate tax and other tax offenses against the Plaintiff; (b) deemed that the Plaintiff received part of the price for interior services (hereinafter referred to as “market price”) of interior services or sales agency services paid to the Plaintiff during the first period of 2013 and second period C, C, D (hereinafter referred to as “D”), and E (hereinafter referred to as “instant purchaser”) during the second period of 2014 as listed in the table as follows (hereinafter referred to as “market price”) by means of receiving a refund of the amount equivalent to the issues through the account of the Plaintiff’s employees and their family members, etc. (hereinafter referred to as “market tax invoice”).

After the Plaintiff’s payment of KRW 29 million to C 12,700,00 on April 11, 2013, 2013, C transferred KRW 12,77 million on the same day to the Plaintiff’s FF account, and re-deposited to B’s H account via B’s Chapter G account, the Plaintiff’s payment of KRW 2,50,000 on September 15, 2014 to C; KRW 66,6,000 on the same date; KRW 2,50,000 on the same date; KRW 30,000 on the same date; KRW 50,000 on the same date; KRW 2,50,000 after the Plaintiff’s payment of KRW 50,000 on the check; KRW 3,00,000 on the same date; and KRW 1,500,000 on the same date, the Plaintiff’s payment of KRW 3,000,000.

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