Seoul Administrative Court-2017-Gu Partnership-60581 (2018.06.01)

Tax withholding obligation in paying domestic source income

In case of income generated from domestic sources without a business place in Korea, a person who pays it shall be liable to withhold 20% of the amount paid.

Article 98 of the former Corporate Tax Act (Special Cases concerning Withholding or Collection for Foreign Corporations)

2018Nu5391 Revocation of disposition of revocation of corporate tax collection

BBB

AA Head of the Tax Office

o October 04, 2018

November 01, 201

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 shall belong to the corporation of April 14, 2016 to the plaintiff for the business year of 2014.

The imposition of tax of KRW 347,018,810 (including additional tax) shall be revoked.

1. cite of the reasons for the written judgment in the first instance;

The first trial except for the reasons written by the court with respect to this case as follows:

Therefore, Article 8(2) of the Administrative Litigation Act, the main sentence of Article 420 of the Civil Procedure Act, because the reasoning is the same as the entry in the reasoning.

this shall be quoted in accordance with this paragraph.

2. The term " June 1, 2014" of the 2nd line shall be " May 19, 2014".

The part "(s)" of 1 line under the second part(s) is "(s) £« + 100:00:00:

hereinafter referred to as the "amount of evaluation of this case" shall be the "amount of evaluation".

4. The calculation of the eight lines below the 4th Schedule shall be added to the following:

2. Conclusion

Since the judgment of the first instance is justifiable, the plaintiff's appeal is dismissed as it is groundless.