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(영문) 울산지방법원 2013.11.07 2013구합547
법인세경정거부처분취소
Text

1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Reasons

1. Details of the disposition;

A. The International Peatum Inc. (hereinafter referred to as the “IPIC”) is a corporation established in accordance with the Abubathy Act of the United States Armed Forces (hereinafter referred to as the “UAE”), and is aimed at investing in the international petroleum-related business in each world while the Abuba Government holds 100% of the share of 100%.

IPR holds 100% of the issued shares of IPRs GmbH (hereinafter referred to as “IPR”) which is a corporation established on 1998 pursuant to the Finland law (hereinafter referred to as “Flagum”) and a corporation established on Austria law (hereinafter referred to as “IPR”) established on 1997.

Meanwhile, the Plaintiff is a legal entity established on September 27, 1999 under the Netherlands Act, and the Flagum holds 75.9% of the Plaintiff’s outstanding shares, and IPIC holds 24.1% of the remainder of the Plaintiff’s outstanding shares, and IPIC holds 99.93% of the issued shares of IP International B.V. (hereinafter “IPIC”) established on January 23, 2006 in accordance with the Netherlands Act, and IPH holding 0.07% of the remainder of issued shares of IPIC.

B. On December 99, the Plaintiff acquired approximately KRW 122,541,211 (50% of the total issued shares) of 12,70,00,000 (one 5,000 won per share) from 12,70,000, and on February 9, 2006, 496 49,016,485 shares (hereinafter “instant shares”) from 220,574,182,50 won (one 4,50 won per share) to 30,50 shares, 205, 208, 140, 208, 208, 140, 208, 204, 30, 140, 208, 140, 205, 140, 208, 308, 140, 184, 206, 304, 184, 106, 1, 48, 1, 1,30, 1.

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