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1. The Defendant’s KRW 63,875,030 as well as the Plaintiff’s annual rate of KRW 5% from November 21, 2017 to November 14, 2018.
Reasons
1. Basic facts
A. During the period from April 2, 2012 to March 31, 2017 with a tax accounting corporation A (hereinafter “A”), the Plaintiff entered into a tax adjustment agreement with A (hereinafter “each of the instant tax adjustment agreements”) stipulating that A shall perform the Plaintiff’s business of tax adjustment to report corporate tax for each business year, and the Plaintiff shall pay A remuneration for tax adjustment for each business year (hereinafter “each of the instant tax adjustment agreements”).
According to the proviso to Article 5 of the Tax Adjustment Agreement of this case, if the Plaintiff becomes liable for a cause attributable to A to the tax adjustment, the penalty tax out of the amount of the additional tax is assessed against A.
B. From July 20, 2017 to August 24, 2017, the director of the Seoul Regional Tax Office conducted a tax investigation with respect to the Plaintiff.
As a result of the tax investigation, A was found to have mistakenly processed the taxable income year by omitting the tax adjustment on foreign currency assets such as foreign currency assets in case of tax adjustment.
C. Accordingly, the corporate tax has been additionally imposed or refunded for each business year as listed below as a result of a change in the amount of corporate tax for each business year, and the local income tax, which is calculated with the amount of corporate tax as the tax base, was additionally imposed or refunded.
In addition, in the business year in which corporate tax and local income tax (hereinafter “corporate tax, etc.”) are underpaid due to such mistakes in corporate tax return and payment, additional taxes are imposed in addition to the amount of taxation, such as corporate tax, as indicated below, and in the business year in which corporate tax, etc. are overpaid, additional dues were refunded to the Plaintiff in addition to the amount of refund, such as corporate tax, as listed below.
(unit: 102,652,430 (Taxation) 10,265,240 (Taxation) 65,240 (Taxation) 2013-8,99,960 (Refund) - 89,99,990 (Refund) - 6,660 - 239,110,370 (Refund) -23,91,030 (Refund) - 176,990 (Refund) - 176,990 (Refund) 9,435,680 (Taxation).