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(영문) 서울고등법원 2016.12.13 2016누55089
법인세부과처분취소
Text

1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

Reasons

1. The reasoning of the court’s explanation of this case is as stated in the reasoning of the judgment of the first instance except for dismissal or addition of the judgment of the first instance as follows. Thus, this is accepted in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

After the first instance court’s “17”, “23,27,28,31, and “B 5” was added to “7” and “6” was added to “7” and “13, 15 of the first instance court’s first instance court’s first instance court’s first instance court’s second instance judgment. On the other hand, the Plaintiff did not pay dividends in the business year 2013 and reserved the income in F. Thus, the actual owner of the pertinent royalty income in the instant case did not pay dividends in light of the high dividend tendency of the European enterprises or FF’s second and second 2011, 2012’s second 201 and 2012’s second 2013 business year. The financial statements of the 2013 business year were prepared on February 14, 2014, which was the first instance court’s first instance court’s second 2013 business year after receiving data from the Defendant and submitted them to the Defendant, and it was difficult to view that the Defendant’s second 2013 business year’s second G.

According to the decision of the first instance court No. 14, the following contents are added to "3 points", and the Hungary is able to attract the film production industry, but the main business related to F's film production is to collect user fees. However, the main business related to F's film production is to collect user fees. On the 14th judgment of the first instance court, the following contents are added to G. The Plaintiff did not play any role in relation to the domestic distribution right of this case, and the Plaintiff did not play any role on January 14, 2016.

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