logobeta
본 영문본은 리걸엔진의 AI 번역 엔진으로 번역되었습니다. 수정이 필요한 부분이 있는 경우 피드백 부탁드립니다.
텍스트 조절
arrow
arrow
(영문) 서울행정법원 2017.01.20 2016구합73542
법인세부과처분취소
Text

1. The plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

Reasons

1. Details of the disposition;

A. Lone Star Fund is an international private equity fund established on July 200, 200, which consists of the Plaintiffs and Hudco Partnership Korea Llodco Partners Korea (Hudcos Korea, Bermuda).

(hereinafter referred to as “Lone Star Funds”) B.

Plaintiff

Lone Star Fund TUS EL (hereinafter “Plaintiff U.S.”) is a limited partnership established under the laws of the State of Deteawa (U.S.) and invested by investors in the U.S. as a partnership. Plaintiff Lone Star Lone Star (hereinafter “Plaintiff Lone Star”) is a limited partnership established under the laws of the State of Lone Star (U.S.) and invested by investors outside the U.S. as a partnership, and is established under the laws of the State of Lone Star Korea Lone Star Korea (U.S.) to provide opportunities to invest in Lone Star Fund TU executives and employees.

C. Lone Star Fund Co., Ltd. established a holding company by jointly contributing funds for the purpose of investing in real estate in Korea, and through the holding company, it was changed into SA and later SCA by the Belgium Act. (hereinafter “SH”).

SH acquired the entire shares of CNP (the name of “stock company” after the acquisition; hereinafter “SP”) to “SPS”) and purchased the land in Gangnam-gu Seoul Eastern 737 and the building on its ground (hereinafter “SPS building”).

SH sells 50% of transfer margin 245,06,185,237 acquisition value of KRW 100,049,095, transfer value of KRW 351,091,149,508, transfer value of KRW 351,508, transfer value of KRW 351,091,149,508, transfer cost of KRW 5,975,949,949,949.

arrow