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(영문) 서울행정법원 2015.02.13 2014구합69945
재산세부과처분취소
Text

1. Plaintiff camcam and the limited company specializing in the cambam-backed investment securitization, and Plaintiff camcambam-backed investment securitization.

Reasons

1. Details of the disposition;

A. On or before January 1, 2014, the date when the Local Tax Act (amended by Act No. 12153, Jan. 1, 2014; hereinafter “former Local Tax Act”) amended (amended by Act No. 12153, Jan. 1, 2014; hereinafter “former Act”) enters into a security trust agreement (transfer of the ownership of real estate to a trust company by the truster to secure his/her own performance, and the trust company shall manage the trust assets to maintain the collateral of the trust assets for a certain period for the creditor, who is the first beneficiary, and the trust company shall liquidates the trust assets to the truster and return the balance to the truster if there is any balance; hereinafter “instant trust agreement”) and was entrusted with the instant trust assets.

B. The Plaintiff czek Japan Specialized in Investment Asset-backed Securitization and Plaintiff cambling Investment Specialized Company (hereinafter “Plaintiff Special cambing Company”) acquired the right to preferential benefit under the instant trust agreement (within the scope of the remaining amount obtained by subtracting the disposal costs of trust affairs, trust fees, etc. from the proceeds of the sale of trust assets, trust fees, etc. and the claims of the senior right holder) and the right to secured debt, and retain it up to the present date, by transfer, throughout December 28, 2009 and December 30, 2010.

C. The Defendants, pursuant to Article 107(1)3 of the amended Act, the main text of Article 1 and Article 17(1) of the Addenda (hereinafter collectively referred to as the “instant Addenda provisions”), against the Plaintiff, who is the trustee of the instant trust property, pursuant to Article 107(1)3 of the amended Act, and Articles 17(1) of the Addenda, the same year.

9. Over 10.0, as shown in Appendix 1 “The Details of Taxation Disposition.”

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