Therefore, it cannot be deemed that there was a high probability that a taxation claim should be established, since there was a tax investigation could not have been predicted.

Since a gift contract was established and a tax investigation was conducted more than 6 months after it was designated as the second taxpayer after 6 months thereafter, it cannot be deemed that the possibility was realized because the tax claim was established in the near future from the date of the gift contract because there was no ground to anticipate the tax investigation.

Article 30 of the National Tax Collection Act

2013 Ghana 21079 Revocation of Fraudulent Act

000

The AA

July 23, 2014

August 1, 2014

1. The plaintiff's claim is dismissed.

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

Cheong-gu Office

1. The contract of gift dated March 7, 2012 between the defendant and the non-party B on the real estate stated in the separate sheet between the defendant and the non-party B shall be revoked.

2. Defendant Jeong-A will implement the procedure for registration of cancellation of ownership transfer registration that was completed on March 14, 2012 by the Daegu District Court 00 branch office of the Daegu District Court 00 branch office with respect to the real estate listed in the attached list to the Plaintiff.

1. The plaintiff's assertion

At a high probability of the establishment of tax liability against the plaintiff of the OOOB, the contract for the gift must be revoked as a fraudulent act, since the contract for the gift is expected to be made on March 7, 2012 to the defendant, the wife, who was the wife, on March 7, 2012.

2. Facts of recognition;

“A. From December 1, 1994 to 1209, the Defendant’s husband’s husband operated CCCPethyl (hereinafter “CCCethyl”) at OO-Gu OO-dong 1209 (hereinafter “CCP”) (BB owned 90.46% of CCCP stocks); CCCP et al. at CCC on October 26, 2010, transferred all its business assets around October 26, 201, and closed its business on March 31, 2012 while there was no business performance after 201; BB donated real estate listed in the attached list to the Defendant, who is the wife, and completed the registration of ownership transfer to the Defendant on March 14, 2012.

C. However, the head of the listed tax office under the Plaintiff’s umbrella found that CCC was underpaid tax by means of collecting low-price rents from affiliates from September 17, 2012 to December 7, 2012 and 2009, including unfair depreciation costs and losses from unused machinery, etc., and did not notify CCCS of the correction of corporate tax for the taxable year 2007 as the due date for payment on February 15, 2013, corporate tax for the taxable year 2008, OOOOOO for corporate tax for the taxable year 2008, 2009, OBB for the taxable year 209 to be the secondary taxpayer under the provisions of Article 39 of the Framework Act on National Taxes, but also did not pay the amount of national tax, 13OB’s respective arguments, 14, 201, 14, 301, 14, 14, 2013

A. At the time of March 7, 2012, there was a high probability that the Plaintiff’s taxation claim against Western was established, and whether the instant taxation claim can be the preserved claim in the lawsuit seeking revocation of the instant fraudulent act due to the establishment of the instant taxation claim in the near future.

B. According to the above facts, the gift contract was concluded on March 7, 2012, and there was a tax investigation on CCCethyl from September 17, 2012, which was six months later, and it was designated on March 6, 2013 by PCCB as the secondary taxpayer of the CCC or other affiliate companies. In the instant case, where BB or the Defendant did not have any evidence that it was possible to anticipate a tax investigation on CCCP as of March 7, 2012, the evidence alone submitted by the Plaintiff was highly probable at the time of the donation contract, and it is difficult to conclude that the instant tax claim was established in the near future from the date of the above donation contract and its probability was realized.

4. Conclusion

Therefore, since the taxation claim of this case cannot be the preserved claim of this case, the plaintiff's claim is dismissed as it is without merit, and it is so decided as per Disposition.