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(영문) 서울행정법원 2016.06.16 2015구합55332
법인세부과처분취소
Text

1. All of the plaintiff's claims are dismissed.

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

Reasons

1. Details of the disposition;

A. 1) The Plaintiff is a domestic corporation that operates the overall content business, and the Category B group is a film producer, a film producer (hereinafter “C company”).

) E, the final parent company, is a global entertainment content group listed in the New York Stock Exchange. It is a company that provides various kinds of entertainment content, including television, film, Internet content, and video games. 2) F company (hereinafter referred to as “F”) is a foreign corporation having a place of business in Hungary and has a foreign corporation on September 8, 2010 under Hungary’s law, and has approximately KRW 50,000 Green (HUF, approximately KRW 2.5 million to KRW 2010 to KRW 2013; hereinafter referred to as “F company”)’s share in the business of distributing film, film, and television, etc.; and it is established as one set of approximately KRW 15-6 per minute for the convenience of calculation.

B. License Agreement, etc. 1) F grants the exclusive right to distribute the film, television program, etc. created by Company B affiliated with G on November 1, 2010 to five countries, including Korea, Japan, Israel, Italy, Hungary, and Hungary, among the right to distribute in the world other than Canada with respect to the film, television program, etc. created by Company B affiliated with G (hereinafter “instant license agreement”).

A. From 2006 to the transfer of the license agreement, the Plaintiff entered into a contract (No. 6) with G (G’s Clbal Business Department) on the domestic distribution right on film, etc. produced by film companies, etc. under B group (hereinafter “instant domestic distribution right”) and distributed to Korea through the Plaintiff’s TV channel (H, I, J, K, K, etc.) by importing film, etc., and the F.

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