Gwangju District Court-2015-Guhap-59 ( November 26, 2015)

High Court 2014 Mine1492 ( October 16, 2014)

The taxpayer has the burden of proving necessary expenses.

It is difficult to readily conclude that the instant remittance was used as a local necessary expense in China only with the submitted evidence.

Article 27 of the Income Tax Act

Gwangju High Court 2015Nu7639 and revocation of the detailed global income and disposition thereof.

AA

BB Director of the Tax Office

Gwangju District Court-2015-Gu Partnership-59

June 9, 2016

October 20, 2016

1. The plaintiff's appeal is dismissed. 2. Costs of appeal are borne by the plaintiff.

The judgment of the first instance shall be revoked. Each disposition of the Defendant rendered against the Plaintiff on December 3, 2013, including KRW 00 of global income tax for the year 2010 and global income tax for the year 2011, shall be revoked.

1. The reason for the judgment of the political party is the evidence additionally submitted in the trial, and the fact of the plaintiff's assertion is recognized.

The judgment of the court of first instance shall be dismissed from each entry of the evidence of No. 15 to No. 22 (including each number), which falls short of

In addition to the provisions of section 7(3) of the sentence, it shall be the same as the reasoning of the judgment of the first instance as follows:

as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

(c)

[Completioned Parts]

③ On 2010 and 2011, the Plaintiff’s Chinese office is operated in the name of the Plaintiff or the right delay.

Party A alleged that it remitted operating expenses to Ma, who is an employee of the Republic of Korea, but Party A 2, 5, 6, 22

It is insufficient to recognize that each description of the certificate was an employee employed by the plaintiff by the lasta alone.

In addition, it can be readily concluded that the remittance was used as the Plaintiff’s office operating expenses.

It is difficult to do so.

2. If so, the judgment of the court of first instance is just and reasonable, and the plaintiff's appeal is without merit.

The judgment is dismissed. It is so decided as per Disposition.