Seoul Administrative Court-2014-Gu Partnership-7388 ( October 10, 2015)

Whether a long-term exclusion period for taxation is applied because the sale of low price of bonds falls under fraudulent or other unlawful acts

In order to manipulate the rate of return on the fund, the low-price sale of the claim corresponding to the act of breach of trust constitutes fraud or other unlawful act, and the period of exclusion for ten years is applied.

Article 26-2 of the National Tax Basic Act

2015Nu47012 Revocation of Disposition of Corporate Tax Imposition

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BB Director of the Tax Office

Seoul Administrative Court Decision 2014Guhap73388 decided May 28, 2015

January 13, 2016

1. The plaintiff's appeal is dismissed.

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

The judgment of the first instance shall be revoked. The defendant's disposition of imposing corporate tax of KRW 1,531,711,030 (including additional tax) for the business year from September 1, 2003 to November 30, 203 against the plaintiff on February 13, 2014 shall be revoked.

1. Quotation of judgment of the first instance;

The reasoning of this court's judgment is the same as that of the judgment of the first instance, and thus, it is cited in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

2. Conclusion

The judgment of the first instance is justifiable. The plaintiff's appeal is dismissed.