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(영문) 서울고등법원 2018.10.05 2018누30992
부가가치세부과처분취소
Text

1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1...

Reasons

1. The reasoning of the judgment of the court of first instance is as follows, except for the dismissal or addition of part of the judgment of the court of first instance, and thus, it is consistent with the reasoning of the judgment of the court of first instance. Therefore, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 4

6 pages 15 " May 14, 2014" shall be changed to " May 2, 2014".

10. The following shall be added to six pages:

No. 10 pages 13, 2012, “No. 26” entered the mandator into the instant contract on February 7, 2012, but each of the executive officers of the instant parent company, not the representative of the instant permanent establishment, signed by each of the executive officers of the instant parent company, and the instant modified contract also signed by the director of the instant parent company, not the representative of the permanent establishment.”

10.On the 20th page, the following shall be added:

In particular, the following shall be added to the phrase "a point of interpretation" of the 11th 17th 11th page "including the global marketing and global communication strategies, cost calculation, etc., in which the permanent establishment in this case is unable to perform in the Republic of Korea:

“In addition, this case’s conclusion of this case’s MOU

2. 7. The purpose of the contract is to grant the delegated person the qualification to conclude the contract under the name of the delegating person as a result of the increase in customer's demand while the delegated person and the delegating person have established a business relationship from the past. Thus, the permanent establishment of this case reported on February 10, 2012 is the case.

2. The following is added to the 12th 8th 12th 8th 12th 12th 8th 12th 1st 8th 2th 2th 200. The Defendant asserted that the above service was supplied to the parent company of this case through the permanent establishment, but the other party who received the above sales support service as seen earlier.

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