Seoul High Court (Chuncheon) 2012Nu237 (Law No. 24, 2013)

early 2010 Heavy2465 ( October 12, 2010)

In title trust, it cannot be readily concluded that there was no intention of tax avoidance in title trust.

Inasmuch as the amount of tax on the dividend income that can be avoided through the title trust is not significant, or there is no reduced tax avoidance or reduced tax on the shares through the title trust, it cannot be readily concluded that there was no intention of tax avoidance in the title trust under tax law in the title trust.

Article 45-2 of the Inheritance Tax and Gift Tax Act

2013Du18339 Revocation of Disposition of Imposing gift tax

AAA

Head of the District Tax Office

Seoul High Court (Chuncheon) Decision 2012Nu237 Decided July 24, 2013

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but the argument on the grounds of appeal by the appellant falls under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal and therefore, the appeal is dismissed in accordance with Article 5 of the above Act. It is so