(1) The association of this case, as the method of distributing profits or the ratio of distributing profits, is determined, members including the Plaintiff, etc. are liable to pay income tax.

It is reasonable to view that the association of this case was determined by the method of profit distribution or the ratio of profit distribution. Accordingly, members, including the plaintiff, are liable to pay income tax on the royalty of this case as joint business operators pursuant to Article 2(3) of the Income Tax Act and Article 2(1) and (2) of the Enforcement Rule

Article 81-3 of the former Framework Act on National Taxes Presumption of Sincerity

2018Nu34444 Global income and revocation of such disposition.

○ Kim

○ Head of tax office

April 25, 2018

June 20, 2018

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The judgment of the first instance is revoked. The imposition of global income tax of KRW 32,046,90 (including additional tax) for the Plaintiff on April 18, 2016 shall be revoked.

1. Quotation of judgment of the first instance;

The reasoning for this Court’s reasoning is as follows: “32,046,90 won of global income tax” under 2 of the first instance judgment is the same as the part of the reasoning for the first instance judgment (excluding the part on 4. conclusion) except that the “32,046,990 won of global income tax (including additional tax)” is deemed to be “32,046,990 won of global income tax”; therefore, this Court shall accept it as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of

2. Conclusion

Therefore, the plaintiff's claim shall be dismissed as it is without merit. The judgment of the court of first instance is just in conclusion, and the plaintiff's appeal is dismissed as it is without merit.