Seoul High Court 2012Nu7716 (22 August 22, 2012)

National Tax Service Review and Transfer 2011-0058 ( October 27, 2011)

(A) If the acquisition value is converted at a conversion price, the necessary expenses may be deducted only from the estimated deduction amount.

(C) In the event that the transfer margin is calculated based on the conversion price and the standard market price, the necessary expenses to be deducted in calculating the transfer margin is only the estimated deduction amount calculated based on the acquisition price calculated by the conversion price and the standard market price. Therefore, the site development cost, alternative forest resources creation cost, etc. shall not be deducted from the necessary expenses.

2012Du21048 Revocation of Disposition of Imposing capital gains tax

Note XX

Head of the tax office;

Seoul High Court Decision 2012Nu7716 Decided August 22, 2012

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the assertion on the grounds of appeal by the appellant constitutes Article 4 of the Act on Special Cases Concerning the Procedure for Appeal and therefore, the appeal is dismissed under Article 5 of the above Act. It is so decided as per Disposition by

Reference materials.

If the grounds for final appeal are not included in the grounds of appeal that make it appropriate for the court of final appeal to become a legal trial, such as matters concerning significant violation of Acts and subordinate statutes, etc., the system of final appeal will not continue to proceed with the deliberation on the merits of the grounds for final appeal, but will not proceed with the deliberation on the merits of the grounds for final