Seoul High Court-2016-Nu-70460 ( October 27, 2017)

Cho High 2015west0468 ( October 18, 2015)

(D) The bonus disposition is legitimate because the special relationship is extinguished due to the ex officio closure of business, and the provisional payment is finally attributed to the representative of the subsidiary of a foreign corporation.

(1) The substance of the domestic business office of China is the subsidiary, and the special relationship between the plaintiff and the plaintiff is extinguished due to the ex officio closure of business, and the provisional payment of this case was finally reverted to the plaintiff, so the disposition of this case which imposed the comprehensive income tax after disposing of it as bonus on the plaintiff

Article 67 of the Corporate Tax Act, Article 11-2 (a) of the Enforcement Decree of the Corporate Tax Act

2017du73006 Action Demanding revocation of Disposition imposing income tax

KimA

BB Director of the Tax Office

Seoul High Court Decision 2016Nu70460 Decided October 27, 2017

15, 2018

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but the argument on the grounds of appeal by the appellant is clear that it falls under Article 4 of the Act on Special Cases concerning the Trial Procedure, and therefore, the appeal is dismissed pursuant to Article 5 of the same Act. It is so decided as per Disposition by the assent