Text
1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
The purport of the claim and appeal is the purport of the appeal.
Reasons
1. The reasoning of the judgment of the court of first instance, such as admitting the relevant part of the judgment of the court of first instance, is as stated in the grounds of the judgment of the court of first instance (excluding the corresponding part of the judgment of the court of first instance) (excluding the corresponding part of the judgment of the court of first instance) unless the relevant part of the judgment is modified as follows 2, and thus, it is acceptable
2. In addition, Article 2(1) of the Addenda (No. 26067, February 3, 2015) of the Enforcement Decree of the amended Act provides that “The term “this Decree shall apply from the income derived from the taxable period in which this Decree enters into force.” From 10th to 11th “The term “the instant disposition” is related to the taxation requirements established on June 30, 2012, it is reasonable to calculate the amount of tax through a reasonable interpretation of Article 22(3) of the amended Income Tax Act, which is the law established at that time. Article 22(3) of the current Income Tax Act provides that “The amount of retirement income payable at the time of retirement on December 31, 201,” and delegates the specific contents to the Presidential Decree, but Article 22(1) of the amended Income Tax Act provides that “the amount of income to be paid at the time of retirement on the 21st day of 20th day of 2012,” which is “the last day of the amendment,”.
If the statute was amended favorably to the taxpayer after the date of establishment of the tax liability, if the amended statute did not have any separate transitional provision on retroactive application, the amended statute may be applied retroactively only on the ground that it was amended favorably to the taxpayer.