1. The Defendant’s disposition of correction and notification of KRW 30,261,950, which the Plaintiff rendered on May 17, 2018, shall be revoked.

2. The costs of lawsuit shall be.

Details of the disposition

The plaintiff is a company established on December 27, 2010 for the purpose of exporting and importing agricultural and fishery products.

The Plaintiff imported a total of 600 tons of FRESON from the Limited Company B (B; hereinafter “B”) which is a Chinese company, and then imported a total of 600 tons from November 21, 2017 to January 9, 2018 to the Defendant.

1. As indicated in the description, the import declaration was filed with C and four cases, including the importation declaration (hereinafter referred to as the “instant goods”), and the unit price of the instant goods was reported to US$ 240 per ton at the time of the import declaration.

(hereinafter “instant declaration price”). From December 4, 2017 to January 12, 2018, the Defendant requested an examination of the dutiable value of the instant goods to the Seoul Customs Office, which is the jurisdiction over the Plaintiff’s place of business.

As a result of the prior tax examination of the instant goods, the Seoul Customs Office requested the Plaintiff on April 13, 2018 to submit data verifying that the instant declaration price is identical to the fact pursuant to Article 30(4) of the Customs Act on the grounds that the instant declaration price is significantly different from the transaction price of similar goods of other companies.

Accordingly, the Plaintiff submitted the business sales contract, remittance statement, cost composition table, etc. to Seoul Customs Office as explanatory materials.

On May 14, 2018, the Seoul Customs Office denied the Plaintiff’s import declaration price pursuant to Article 30(5) of the Customs Act by deeming that the Plaintiff could not trust the accuracy or truth of the declared price because the Plaintiff failed to clearly explain the significant difference between the declared price and the similar price, and determined the dutiable value based on the minimum market price of similar goods pursuant to Article 32 of the Customs Act.

The defendant shall attach attached Form to the plaintiff on May 17, 2018.

1. A total amount of KRW 30,261,940 on the instant goods, such as the description of the details, was corrected and notified.

(hereinafter “instant disposition”). The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on August 10, 2018, but on January 10, 2019.