logobeta
본 영문본은 리걸엔진의 AI 번역 엔진으로 번역되었습니다. 수정이 필요한 부분이 있는 경우 피드백 부탁드립니다.
텍스트 조절
arrow
arrow
(영문) 서울고등법원 2018.12.05 2018누56260
취득세등부과처분취소
Text

1. Revocation of the first instance judgment.

2. Acquisition tax amounting to KRW 942,932,070 (including additional tax) imposed on the Plaintiff on January 20, 2015, as well as KRW 942,932,070.

Reasons

1. The reasoning of the judgment of the court on this part of the grounds of the disposition is as follows, except for amendments as follows, and thus, this part of the judgment of the court of first instance is identical to the corresponding part of the judgment of the court of first instance.

3. The 11,645,482,637 won (=the net asset value of C as of the date of integration 11,847,647 - the total par value of 58,802 shares - the total issued value of 58,802 shares - 202,640 won per share of 58,802 shares) added 3.6 6 6 4 2 4 2 2 4 2 3 3 3 4 3 3 4 3 4 3 4 3 4 4 3 4 3 4 4 444 3 444 3 4 4 3 44 4 44 4 4 3 46 4 4 4 3 4 4 4 3 4 4 4 3 4 4 4 4 4 3 47 4 4. 4 4 4 7 4 4 4 7 4 4 4 4 4 4 4 4 4 4 . 7. 3 4 . . 3 4 4 . . 3 4 4 . 4 . . . .

2. The details of the relevant Acts and subordinate statutes are as shown in attached statutes;

3. Whether the instant taxation disposition is legitimate

A. The Plaintiff’s assertion 1) As of June 30, 2013, which was the date of the integration between the Plaintiff and C, the net asset value of C is KRW 11,847,644,277, and as of June 30, 2013, B, a small and medium business proprietor of the place of business (C) extinguished by the instant integrated contract, acquired the Plaintiff’s shares 3,446,087 shares (total share value of KRW 11,847,64,277) from the Plaintiff on seven occasions, in return for the said integration.

arrow