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(영문) 부산지방법원 2017.06.23 2016구합24411
법인세등부과처분취소
Text

1. The plaintiff's claim is dismissed.

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

Reasons

1. Details of the disposition;

A. The Plaintiff purchased a mobile device on credit from SK Telecom Co., Ltd. (hereinafter “stock company”) which is a mobile communications service provider, and sold it on credit to the subscribers to the mobile communications service, and paid cash to the subscribers to the mobile communications service after receiving fees from SK Telecom in return for the mother’s payment, or paid the installments, penalties, etc. of the existing mobile device on behalf of the subscribers.

B. As a result of the Busan National Tax Service’s consolidated investigation into the Plaintiff from September 15, 2014 to November 13, 2014, the Plaintiff, as listed in the following table, omitted sales revenue of KRW 20,515,824,23 of the amount of subsidies paid from the sales of telecommunications equipment (i.e., parent-child subsidies, etc.) from January 1, 2009 to December 31, 2013, and omitted sales revenue of KRW 7,838,240,00 and the amount of rental fees of KRW 180,228,227,08,227, including total amount of KRW 8,018,468,227, and KRW 127,927,106,106,391,985,9757,596,597,57,596,57,97, and other expenses for sales sales, etc.

209 3,95, 526, 199, 2304, 304, 257, 364, 275, 3625, 367, 364, 367, 478, 364, 268, 260, 268, 208, 205, 204, 206, 3425, 367, 464, 475, 1974, 467, 1974, 2547, 1947, 2547, 1964, 1967, 1964, 197, 1964, 1964, 1967, 197, 1964, 197, 194, 2567, 1974, 2574, 1967

C. The Commissioner of the National Tax Service of Busan shall notify the Defendant of the correction and notification of the value-added tax from the second to the second half of 2009 and the corporate tax from the 2009 to the 2013 business year.

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