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(영문) 대전지방법원 2016.07.14 2015구합105499
법인세(원천징수분) 징수처분 무효확인
Text

1. The Defendant’s corporate tax for the year 2005 for the Plaintiff on July 6, 2015 (the amount withheld) shall be KRW 8,936,759,890.

Reasons

1. Details of the disposition;

A. On June 19, 2001, UBS Capital B.V., as the Netherlands, and Korea Conferny (Luxembourg) S.A.R.L (hereinafter “KCLuxembourg”), AOF Hai (Luxembourg) S.A.R.L (hereinafter “AF Luxembourg”) established Korea Conferboldings NV (hereinafter “KCH”) as a Belgium, a corporation, as the Belgium on June 19, 2001.

B. Of the shareholders of KCH, the shareholders of Luxembourg are only cases holding 6.6% of the 66.6% of the shares, which are corporations of Ireland (hereinafter “CVC Asian”), and the GLC, a corporation of the United States, which holds 33.4% of the 33.4% of the shares in the 36.4% of the shares. The shareholders of the AOF Luxembourg are the shareholders of AOF Haita Ltd (hereinafter “AUF case”), and only cases holding 10% of the shares are AOF Hai Ltd (hereinafter “AF case”). The shareholders of the AOF case are many of the U.S. corporations including the JPMMMMers.

[Afforestation] The name of KCH superior investors using an abbreviationd name among KCH superior investors [Ge one] shall be as follows:

CSAP: Pocific LAcific L.P. AI LLC: Hocific L. LAcific LAcifoniansian LAcifed Liba AOF Haitaceman: AOF Hai AOF Haitaceman: Haita Haita Haitaceman: Haita Haita Haita Haita Haitaeman: 27 persons under the name of top-tier investors with mutual equity interests in the Netherlands established in the Netherlands in 203, including old neglects and directors’ seating. The left part of the title refers to the country of residence, the percentage of KCH stocks held by OCH.

KCH acquired on July 12, 200 70,000 won for the manufacture and business part of the domestic corporation H&C corporation (hereinafter “instant shares”). After KCH established the Plaintiff for the purpose of producing and selling dry milk products and frozen foods by becoming a 100% shareholder, KCH owned 2,810,000 shares equivalent to 10% of issued shares (hereinafter “instant shares”).

(c) Cown Agenda and Military Personnel Mutual Aid Association, etc. shall organize a consortium;

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