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(영문) 서울행정법원 2014.02.25 2012구합5879
법인세등부과처분취소
Text

1. As against the Plaintiff on March 3, 2010 by the director of the Geumcheon District Tax Office:

(a) Corporate tax of KRW 1,027,853,010 for the business year 2005;

Reasons

1. Details of the disposition;

A. The Plaintiff (the former trade name is “stock company H”) is a company that runs the construction business, electrical construction business, fire fighting business, etc. in Geumcheon-gu Seoul Metropolitan Government I.

B. From October 29, 2009 to January 29, 2010, the director of the Seoul Regional Tax Office conducted a tax investigation with respect to the Plaintiff. From 2005 to 2008, the director of the Seoul Regional Tax Office investigated the cost of outsourcing service, which was returned to the account of the Plaintiff’s employee, 83,967,319 won (398,817,200 won, 301,942,254 won, 183,207,865 won, and the cost of daily labor work, 1,073,879,393 (205 won, 707,825, 62, 2086, 2085, 2086, 2087, 2086, 2086, 257, 2005, 2086, 20086, 2586, 2007, 2867

C. According to the taxation data notified as above, when calculating corporate tax from the business year 2008 to the business year 2008 of the Plaintiff, the head of the tax office of the Geumcheon District Tax: (a) deemed the outsourcing service cost of 883,967,319 won and the daily labor cost of 1,073,879,393 as the processing cost; and (b) disposed of as a bonus to the relevant employee; (c) when calculating the value-added tax for the above period, the head of the tax office deducted the input tax amount related to the outsourcing service cost of 883,967,319 won from the deduction of the input tax amount related to the outsourcing service cost of 883,967,319 won; and

(hereinafter referred to as “the instant disposition of imposition of the corporate tax” and “the instant disposition of imposition of the value-added tax”; 1,027,853,010 won (including additional tax 359,245,895), 210,019,03 won (including additional tax 10,474,691 won) 16,019,230 won (including additional tax 10,474,691 won) 708,54,54,547,547 won (including additional tax 5,936,634 won) in 2006, 206

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