Seoul High Court 2014Nu54594 ( November 27, 2014)

(C) No deficit brought forward shall be succeeded unless all of the requirements for succession to a loss brought forward under the former Corporate Tax Act are met.

(1)In the case of a merger between the subsidiaries with full completed parts, if the merged corporation merges with the merged corporation by allocating one new shares of the merged corporation to the entire shares of the merged corporation, the initial disposition that did not meet the requirements for succession to losses carried forward as provided by the former Corporate Tax

2014Du47365 Revocation of Disposition of Imposing Corporate Tax

AA Engineering Corporation

b Head of the Tax Office

Seoul High Court Decision 2014Nu54594 Decided November 27, 2014

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the assertion on the grounds of appeal by the appellant constitutes Article 4 of the Act on Special Cases Concerning the Procedure for Appeal and therefore, the appeal is dismissed under Article 5 of the above Act. It is so decided as per Disposition by