Seoul High Court 2011Nu17006 ( October 25, 2011)

National Tax Service Review Additional 2010-0169 ( November 01, 2010)

(C) The tax base of the corporate tax shall be determined prior to the disposition of tax imposition, and shall not be deemed to be an administrative disposition subject to appeal.

(b) The tax base determination of corporate tax is a prior decision of the tax imposition disposition, which does not take effect immediately, and it does not have any way to dispute the taxation disposition when the tax imposition disposition is made later, and it cannot be deemed as an administrative disposition that is the object of the immediate appeal lawsuit by the tax authority.

2011Du29739 Revocation of Disposition of Imposing Corporate Tax, etc.

AA Corporation

port of origin

Seoul High Court Decision 2011Nu17006 Decided October 25, 2011

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

In accordance with Article 8(2) of the Administrative Litigation Act, Article 429 of the Civil Procedure Act, and Article 5 of the Act on Special Cases Concerning the Procedure of Final Appeal, it is so decided as per Disposition by the assent of all participating Justices on the bench.

Reference materials.

If the grounds for final appeal are not included in the grounds of appeal that make it appropriate for the court of final appeal to become a legal trial, such as matters concerning significant violation of Acts and subordinate statutes, etc., the system of final appeal will not continue to proceed with the deliberation on the merits of the grounds for final appeal, but will not proceed with the deliberation on the merits of the grounds for final