Law Firm 46012-802 (Law Firm 1996.03.13)

A corporation

In transferring land under long-term installment terms, where a purchaser uses and benefits from the land after the date of the transfer contract, and the purchaser bears the taxes, such as aggregate land tax, imposed on the assets, the taxes borne by the purchaser shall not be included in the transfer value of the relevant land.

In the case of your interpellation, if the corporation transfers land under the long-term installment plan, after the date of the transfer contract, the purchaser bears the taxes, such as the aggregate land tax, etc. (excluding the special surtax) imposed on the property when the purchaser uses and benefits from the property, the taxes borne by the purchaser shall not be included in the transfer value of the land

Article 59-2 of the Corporate Tax Act

1. A summary of the contents of inquiry;

○ In transferring land held by the Government Employees Pension Corporation on a long-term installment basis, the purchaser shall bear the taxes (excluding special surtax) imposed on the land after the date of the transfer contract.

(a) Whether the transfer value of the various taxes borne by the purchaser is included;

(b) The method of including the various taxes borne by the purchaser in the transfer value;

2. Relevant tax-related Acts and subordinate statutes (Acts, Enforcement Decree, Enforcement Rule, and General Provisions);

○ Article 59-2(6) of the Corporate Tax Act

Article 124-2(13) of the Enforcement Decree of the Corporate Tax Act

【Time of transfer or acquisition】 Article 53 of the Enforcement Decree of the Income Tax Act