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Reasons
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(영문) 대구고등법원 2019.04.26 2018누3142
종합소득세부과처분취소
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1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

Reasons

1. Details of the disposition;

A. The Plaintiff’s global income tax return and payment 1) The Plaintiff is a multi-level marketing company B (hereinafter “B”).

(2) The Plaintiff reported and paid KRW 136,613,440 of global income tax for the year 2012, global income tax for the year 2013, and KRW 99,740,030 of global income tax for the year 2013, and KRW 171,236,019 of global income tax for the year 2014, as indicated below.

[Attachment 1] Details of disposition of global income tax for the year 2012 to 2014

B. From March 30, 2016, the Defendant issued a tax investigation and a disposition of increased or decreased tax assessment for the same year.

4. By the 16th day, an investigation was conducted on the Plaintiff.

As a result, the Defendant determined that the Plaintiff included KRW 348,086,710,710, which was appropriated as necessary expenses in response to KRW 4,071,683,181 at the time of filing a global income tax return for the year 2012 to 2014 (i.e., KRW 82,195,220, KRW 914,110, KRW 173,97,977,345, and entertainment expenses for the overlapping amount of KRW 48,340,70,285 (= KRW 491,06,636, 2013, KRW 446,9716, KRW 2014, KRW 2013).

2) On July 1, 2016, the Defendant notified the Plaintiff of the total income tax for the year from July 1, 2012 to 2014, as indicated in the column for correction of the amount of KRW 1,331,956,206 in the entertainment expense limit of KRW 1,340,770,285 as entertainment expense, and KRW 48,345 as entertainment expense, and KRW 1,331,956,206 as entertainment expense, and the Defendant did not include the amount of KRW 1,331,956,206 as entertainment expense, as necessary expense. (c) On September 30, 2016, the Plaintiff filed an objection with the Director of the Daegu Regional Tax Office to correct the amount of income tax for the year from 2012 to 2014 as stated in the column for correction of the amount of income tax for the year from 2016 to 2016.

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