Seoul High Court-2014-Nu-54389 ( October 26, 2015)

(C) It is difficult to deem that the subject who started construction under Article 46-2 (1) 5 of the Enforcement Rule of the Corporate Tax Act is limited to the owner of the land.

(C) It is difficult to deem that the owner of the land shall be limited to the owner of the land who started the construction of the land from the "land on which the construction was commenced to acquire the land on which the building is not settled on the ground.

Article 46-2 (1) 5 of the Enforcement Rule of the Corporate Tax Act

2015Du41142 Revocation of Disposition of Corporate Tax Imposition

AAA Holdings Co., Ltd.

The Director of Gangnam District Office

Seoul High Court Decision 2014Nu54389 Decided March 26, 2015

The appeal is dismissed.

The costs of appeal are assessed against the defendant.

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