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Reasons
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(영문) 서울행정법원 2014.06.05 2012구합20199
종합소득세부과처분취소
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1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

Reasons

1. Details of the disposition;

A. The plaintiffs are certified public accountants (hereinafter "C") from March 2005 to December 31, 2008.

(2) Around June 30, 2008, before retirement, the Plaintiffs entered into an agreement with C as a director. Around June 30, 2008, respectively.

Except for the amount of money received under the contract, the same content is identical. However, the Plaintiff’s argument regarding the meaning of set management is expressed as “settlement” in consideration of the prior meaning or the circumstances concluded in relation to resignation and retirement from the company; hereinafter “instant contract”). From C in the instant contract, the Plaintiff agreed upon KRW 1,313,00,000 for a total of five years under the name of “Set Management A”, and KRW 80,418,000 over two years under the name of “Losss Reunitt”, and the Plaintiff B was paid KRW 1,125,90,000,000 for five years under the name of “Set Management Ambreunitt”, and the Plaintiff was paid KRW 208,280,280,000 for each five years under the pretext of “Set Munitt”.

3) C is for the settlement of accounts in 2009 and 2010 as follows, KRW 525,20,000 to Plaintiff A, and KRW 450,360,000 to Plaintiff B (hereinafter “instant settlement”).

2) Each of the instant damages reserve amounts to KRW 80,418,000 for the Plaintiff and KRW 43,828,000 for the Plaintiff and KRW 43,828,00 for the Plaintiff (hereinafter “instant damages reserve”).

209. The amount paid for the year to which the plaintiff's classification belongs (the amount paid for the year to which the plaintiff's classification belongs 2009.262,60,000 2010 262,600,000 209,209,000 200 2010 40,209,209,2000 B 225,180,000 2025,180 200 2025,180,000 2025,180,000 209 21,914,000 200 201,914,000 200 2010

B. The disposition of global income tax imposition 1C considers the instant settlement amount and the compensation reserve as an honorarium and does not deduct necessary expenses as other income, and 20% of the amount paid as income tax.

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