1. The plaintiff's appeal is dismissed.

2. The plaintiff shall bear the total costs of the lawsuit after filing the appeal.

purport, purport, and.

Details of the disposition

The reason for this decision concerning this part is that the relevant part of the judgment of the court of first instance is identical to the relevant part of the judgment of the court of first instance, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

The 4th parallel 2nd parallel 3th parallel 3th parallel 4th parallel 3th parallel 3th parallel 3th parallel 3th parallel 3th parallel 2

The overall part of the 4th 6th 6th 7th 6th 7th 6th 6th 7th 7th 7th m [the part concerning the income attributed to the above CVI Asia (1,006,336,250 won) in the disposition of corporate tax collection by the defendant is finalized in the remanded judgment, and the part concerning the income attributed to the court (1,006,336,250 won in excess of 1,06,36,250 won) is the part concerning the above CVIP income belonging to the court (1,06,36,250 won in the disposition of corporate tax collection.]

The Plaintiff’s assertion as to the legitimacy of the instant disposition should be revoked on the following grounds.

B Since it is apparent that the Plaintiff is the Plaintiff and the Plaintiff is a resident in the Belgium pursuant to the Korea-Belgium Tax Treaty, denying B’s substance by applying the substance over form principle, which is merely a legal principle under the domestic law, and allowing the Plaintiff, who is only a withholding agent, not a taxpayer, to identify the actual owner of the transfer income of the instant shares, and bear withholding obligations on the Plaintiff, which is also a withholding agent, violates the principle of proportionality as it violates the principle of strict interpretation of the no taxation without law and the tax treaty and excessively expands the burden of the withholding agent.

B as an investment holding company and so-called SPC (Specitu) with a legitimate business objective of holding stocks of DMP, not an Dor corporation established for the purpose of tax avoidance.