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Reasons
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(영문) 서울행정법원 2015.06.05 2013구합13457
법인세경정거부처분취소
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1. The Defendant’s corporate tax amount withheld for July 2009, which was paid by the Plaintiff on August 27, 2012 to the Plaintiff, KRW 1,513,440,00 and KRW 283.

Reasons

1. Details of the disposition;

A. The Plaintiff is a corporation of the United States of America (hereinafter referred to as the “U.S.”), and holds a number of patent rights registered in the United States (such as patent rights No. 5,235,635).

B. Around October 18, 2007, the Plaintiff filed a lawsuit against the Plaintiff’s patent right of the U.S. (U.S. Patent No. 5,592,555, 5,771, 394, 502, 502,689, 5, 247, 621) and the Eastern District Court of the U.S. Tech (U.S.) (U.S.) (U.S.) filed a claim for the prohibition of patent infringement and damages against the Plaintiff’s patent right of the U.S. (U.S. Patent Number No. 5,592,575, 571, 394, 502, 509, 5, 247, 621) with ELS and ELS E. ELS (U.S.).

(hereinafter “instant patent infringement lawsuit”). C.

On April 9, 2009, the Plaintiff and ELJ entered into a patent license agreement and a compromise agreement (hereinafter “instant reconciliation agreement”) with the main contents of the termination of the instant patent infringement lawsuit and the grant of a patent license to ELB. The main contents are as indicated in the instant reconciliation agreement.

On July 20, 2009, ELI paid 8 million US dollars to the Plaintiff in return for the grant of a patent license and exemption from a patent license, and the non-instigation of a lawsuit agreement, and withheld corporate tax of 1,513,440,000 US dollars (US$ 1,200,000), whichever is 15% among them. In return for the transfer of patent rights, ELI paid 1,500 US dollars 1,500,000 US dollars, whichever is 283,770,000 of which is 15% among them, and withheld corporate tax of 2,500 US dollars ($ 25,000).

(4) The Plaintiff paid 9.5 million US dollars to the Defendant on or before August 10, 2009 according to the instant reconciliation agreement (hereinafter “the instant reconciliation agreement”). The ELE reported and paid each withheld corporate tax to the Defendant around August 10, 2009.

E. The Plaintiff on April 12, 2012.

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