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(영문) 서울고등법원 2017.07.19 2016누55119
종합소득세부과처분취소
Text

1. The plaintiff's appeal is dismissed.

2. The defendant's appeal is dismissed.

3. The costs of appeal shall be borne respectively by each party.

Reasons

1. The reasoning of the judgment of the court of first instance, such as accepting the judgment of the court of first instance, is as stated in the reasoning of the judgment of the court of first instance, except to supplement or add the judgment as stated in the following (3). As such, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. From 3 pages 2, 3 to 2, the following is added. The Defendant: (a) from 2007 to 2011, deducted income tax (70,58; (b) 151,260 for the year 2008; (c) 670,767 for the year 209; (d) 871,751 for the year 2010; (c) 32,689 for the year 201; (d) 32,689 for the total amount; (d) 8,087,07,000 for the global income tax on the Plaintiff; (d) 151,260 for the year 207 to 2011; (e) 2,087,04 for the global income tax on the Plaintiff; and (e) 2,014 for the global income tax on the year 207 to 204; and (e) 2, 20014 years to 201 for the global income tax on the Plaintiff.

(B) The Plaintiff notified the Plaintiff of the imposition of global income tax as of March 8, 2013, and the remaining portion of the imposition disposition of global income tax as of March 8, 2013 is the “instant disposition.”

1.3 to 12.0.0....................................

3. Supplementary and additional Plaintiff asserts as follows.

In addition to the tax paid by the Defendant to China (income tax paid to the tax office in the city of granchi), the Plaintiff paid the total amount of 4,245,294 from 2007 to 2014 to the State Tax Office in the city of North Korea.

This is the tax that the plaintiff received from the above limited liability company while mediating transactions with the limited liability company for investment advisers in North Korea.

The income tax paid by the plaintiff to the State Tax Office in China is deducted.

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