1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Details of the disposition

The plaintiff is a domestic corporation running the insurance business, 2013

3. From January to December 31, 2016, the term “investment content” in attached Table 2 is installed in the Plaintiff’s company using equipment or systems, etc., such as each description, and the term “investment amount” in the same Table means the information protection system (hereinafter referred to as “instant system”). Article 25(1)9 of the former Restriction of Special Taxation Act (amended by Act No. 14390, Dec. 20, 2016; hereinafter the same shall apply) applies to each installation cost indicated in the same Table, which was amended by Act No. 12853, Dec. 23, 2014; hereinafter the same shall apply). However, the former Restriction of Special Taxation Act applies to the Plaintiff’s company, as there is no substantial change in the content.

(hereinafter the same shall apply)

(hereinafter referred to as “instant legal provisions”) subject to the tax credit under the instant legal provisions, each of the business years (from March 1, 2013 to December 31, 2013), 2015 (from January 1, 2015 to December 31, 2015), and the business year (from January 1, 2015 to December 31, 2015), paid corporate tax for 2016 (from January 1, 2016 to December 31, 2016).

The Defendant determined that the instant system does not correspond to “facilities to prevent technology leakage” under the instant legal provision, and determined that the Plaintiff’s correction and notification of each corporate tax (hereinafter referred to as “each of the instant dispositions”) as indicated in the “disposition Date” column as indicated in the attached Table 1 attached hereto.

On April 15, 2018, the Plaintiff filed a tax appeal, but was dismissed on July 31, 2019.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 4 (including branch numbers; hereinafter the same shall apply) and the overall purport of each disposition of this case as to the legitimacy of each disposition of this case, the plaintiff's system of this case is "information protection system" as "information protection system" under Article 13 (7) [Attachment 8] of the former Enforcement Rule of the Restriction of Special Taxation Act (amended by Ordinance of the Ministry of Strategy and Finance No. 614, Mar. 17, 2017) (hereinafter the "Enforcement Rule of this case") 2.