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(영문) 서울행정법원 2015.11.20 2015구합54216
법인세부과처분취소
Text

1. The business year of the Plaintiff for the business year of 2008 on June 26, 2013 against the Plaintiff is April in the year immediately preceding the 2008.

Reasons

1. Details of the disposition;

A. The Plaintiff’s status as a foreign securities company, which has its head office in the UK, is a foreign securities company that runs the securities business, and has established a business office in the form of a branch office in Jung-gu Seoul, Jung-gu, Seoul, in order to conduct the sale and purchase of securities and stock index, futures options

(b) Stock warranty securities and liquidity supplier 1) Stock warranty securities (Equitable Linked Want, ELW) stock warranty securities (hereinafter referred to as “ELW”).

Article 2-3(1)6 of the former Enforcement Decree of the Securities and Exchange Act (repealed by Article 2 of the Addenda to the Enforcement Decree of the Financial Investment Services and Capital Markets Act, No. 20947 of July 29, 2008) (amended by Presidential Decree No. 20947 of the Financial Investment Services and Capital Markets Act) provides that securities issued in accordance with the standards prescribed by the Enforcement Rule of the Securities and Capital Markets Act shall be repaid at maturity by one of the parties’ unilateral declaration of intention in connection with the price of specific stock certificates traded at the securities market, the KOSDAQ, or a foreign market similar thereto or the price of stock index, or a call option (e.g., stock certificates) that can be converted into the price of underlying assets at the predetermined time in connection with the change in the stock price or the price of stock price index. However, if the maturity assessment price of underlying assets exceeds the exercise price by comparing the maturity assessment price of underlying assets at maturity with the price of underlying assets at maturity, the issuer shall pay the remaining amount after deducting the exercise price at maturity price at the securities market (see Article 2029(3). 29(3).4.29).203).

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