1. The plaintiff's claim is dismissed.

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

Details of the disposition

The plaintiff has been established on October 2, 199 and operated a business by paying provisional payment to the representative director who is a specially related person, as a corporation that runs the wholesale business of animal drugs.

In accordance with Article 89(3) of the Enforcement Decree of the Corporate Tax Act for calculating the market price (the price applied or deemed as applicable to ordinary transactions between persons who are not related parties) under the denial of wrongful act and calculation under Article 52 of the Corporate Tax Act, the Plaintiff selected the interest rate under the following rate under Article 89(3) of the Enforcement Decree of the Corporate Tax Act for calculating the provisional payment interest rate under the current interest rate under the current interest rate under the current interest rate in 2010, 2011, 2013, 2014, 2014, when filing a corporate tax return on the current interest rate in 2010 through 2015, the Plaintiff reported and paid the corporate tax on the current interest rate in 2010 to the representative director who is related parties.

On March 15, 2017, the Defendant again calculated the recognized interest rate in the business year 2014 and 2015 and notified the Plaintiff of the corrective disposition of corporate tax stated in the attached Table (hereinafter “instant disposition”) against the Plaintiff on the ground that “In the event that the interest rate in the current loan is selected as the market price, the current loan interest rate shall be the market price for the business year and the two following business years.” Since the Plaintiff selected the current loan interest rate in the business year 2013, the current loan interest rate shall be applied even in the business year 2014 and 2015.”

[Ground of recognition] A without dispute, Gap evidence Nos. 1 through 3, Eul evidence Nos. 1 and 2 (including additional numbers), and the purport of the entire pleading as to the legitimacy of the disposition of this case as to whether the disposition of this case is legitimate, the Enforcement Decree of the Corporate Tax Act amended by Presidential Decree No. 22577, Dec. 30, 2010.