Seoul High Court-2018-Nu-4354 (Law No. 19, 2018)

Appellate Court 2017J 2374 (Law No. 17, 2017)

The time of transfer of contribution in kind in the promotion of incorporation for a stock company shall be deemed to be the time of registration of establishment that acquires the status of a shareholder.

(C) The court below's decision is justified as follows: (a) in the case where a corporation subject to the carried-over taxation of the transfer income tax following the conversion into a corporation disposes of 50/100 or more of the shares acquired by the conversion into a corporation; and (b) in the case of incorporation incorporation incorporation registration, the time of transfer of the shares acquired by the corporation as a shareholder; and (c) in the case that the company

Article 32 of the Restriction of Special Taxation Act carrying forward taxation of capital gains tax following the conversion into corporation.

Supreme Court-2018-Du-55012 Revocation of Disposition of Imposing capital gains tax, etc.

United StatesA

s. Head of the tax office

July 19, 2018

December 13, 2018

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

While examining the grounds of appeal in comparison with the records of this case and the judgment of the court below, the argument on the grounds of appeal is not deemed to include or not accept the grounds of appeal under the subparagraphs of Article 4(1) of the Act on Special Cases Concerning the