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(영문) 서울행정법원 2015.07.03 2014구합67444
법인세경정청구거부처분 취소청구의 소
Text

1. The Defendant limited to Korea Savings Bank Co., Ltd. on November 28, 2012, from July 1, 2008 to June 30, 2009, and from June 28, 201 to June 30, 2009.

Reasons

1. Details of the disposition;

A. The Korea Savings Bank Co., Ltd., a corporation carrying on the financial business (hereinafter “Bankruptcy Corporation”) transferred the insolvent project financial bonds (hereinafter “bonds subject to the settlement after death”) to the Korea Asset Management Corporation along with collateral as set out in Table 1, and in return, the Korea Asset Management Corporation acquired the fluctuation interest rate-free private equity bonds (hereinafter “instant private equity bonds”) from the Korea Asset Management Corporation.

(1) On December 30, 2008, December 30, 201, the due date for the acceptance of private equity bonds issued on the date of transfer of the bonds subject to the ex post facto settlement or the acceptance of the bonds issued on the date of the transfer of the bonds issued on December 30, 2008;

B. A bankrupt corporation agreed to pay to the Korea Asset Management Corporation the amount of ex post facto settlement when the amount of claims subject to ex post settlement becomes final and conclusive due to the completion of the sale of securities on the claims subject to ex post settlement, etc.

C. From July 1, 2008 to June 30, 2009 and from July 1, 2009 to June 30, 2010, a bankrupt corporation included interest income on privately placed bonds and other liabilities (such as estimated loss amount, interest expenses, and other management expenses) as shown in the following table 2 in the business year from July 1, 2008 to June 30, 2009. The interest expenses, etc. on bonds subject to ex post facto settlement of accounts shall be deemed deductible expenses for the business year in which the date of settlement of accounts falls, and thus, the interest income on privately placed bonds was adjusted by tax adjustment as deductible expenses, but the corporate tax was reported without a separate tax adjustment.

The list 2: (a) the details of interest on privately offered bonds and other appropriation liabilities (unit: unit) from July 1, 2008 to June 30, 2009 to July 1, 2009 to June 20, 2009.

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