Seoul High Court-2016-Nu-47453 (2017.06.01)

Cho-2014-west-4491 (Law No. 10, 2015)

(C) If the Non-Performing Loan Resolution Fund falls under a non-profit domestic corporation under the Corporate Tax Act, it is not acceptable to accept the Plaintiff’s Note on a different premise.

(F) The Non-Performing Loan Resolution Fund is a foundation with basic property for the public interest under Article 13 (1) 2 of the Framework Act on National Taxes, and thus falls under a non-profit domestic corporation under the Corporate Tax Act. The value of assets received without compensation means the value of assets received without any consideration or compensation for improving the financial structure of the foundation.

Article 18(8) of the Corporate Tax Act provides for exclusion from taxable income

2017du52306 Disposition of revocation of revocation of corporate tax rectification

○ Bank and 14

○ Head of Tax Office and 8

Seoul High Court Decision 2016Nu47453 Decided June 1, 2017

October 31, 2017

All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

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 appellant's grounds of appeal fall under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal and therefore, all of the appeals are dismissed pursuant to Article 5 of the same Act. It is so decided as per Disposition by