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(영문) 서울행정법원 2014.11.20 2014구합57942
법인세등부과처분취소
Text

1. On October 2, 201, the Defendant Heavy Tax Office imposed corporate tax amounting to KRW 435,267,430 on the Plaintiff in 209.

Reasons

1. Details of the disposition;

A. The Plaintiff is a legal entity whose main business is to operate a casino exclusively for foreigners (hereinafter “the instant casino”) in the hotel in Gwangjin-gu Seoul Special Metropolitan City, provokingn of Skylland.

B. On January 25, 2008, in order to attract Chinese customers to the instant casino, the Plaintiff: (a) obtained evidence A of the Joint Venture Contract No. 6, hereinafter referred to as “instant contract,” with the Republic of Korea, a corporation specializing in solicitation of foreign customers, the Philippines, a corporation specializing in solicitation of international customers; (b) and (c)

(1) The following [the amount stated in Table 1 below is the key issue amount] as a result of the customer's game for which training, etc. has been recruited:

[Attachment 1, unit: 13,614,195,00 for the second period of 2, 2009 for the first period of 6,272,786,3209 for the first period of 2,009 for the first period of 4,941,049,000 for the first period of 2,009 for the second period of 2,009,351,400 for the first period of 1,54,893,000 for the second period of 2,2010 for the second period of 13,614,195,00

C. In addition, on December 29, 2008, the Plaintiff purchased a total of 32,969 square meters of land (land subject to district unit planning; hereinafter “instant land”) other than 152 and 4 lots of land in Gwangju City, which is owned by the Plaintiff, as of December 31, 2008, as the largest shareholder holding 37.39% of the Plaintiff’s equity as of December 31, 2008. The Pakistan global is the largest shareholder holding 37.39% of the Plaintiff’s equity as of December 31, 2008.

(Attachment 2) [Attachment 2] [Attachment 2] . [Attachment 2] 31,319,32,000,000, 000 32,094,980,000, 156-2,132, 132, 209-4, 132, 32,969-4, 32,000, 32,000, 153, Song-dong, Gwangju-si, Gwangju-si, 156-2, 793, Song-dong, 156-2, 132, 132, 209-4, 132,00,000,000, 32,094,980,000

D. The director of the Seoul Regional Tax Office, upon conducting a tax investigation against the plaintiff, receives the issue amount of this case that the plaintiff paid to the training, etc. from a foreign corporation with no domestic place of business related to the business on which the value-added tax is not levied.

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