Seoul High Court-2013-Nu-20235 (Law No. 24 April 2014)

(C) The tax credits for research and development expenses under Article 10 (1) of the Restriction of Special Taxation Act shall be granted in the case of re-entrustment to a third party.

As long as research and development services have been entrusted to a recipient company with the department in exclusive charge (the main point of the original trial), the expenses still constitute the subject of tax credit even if the contract is re-entrusted.

Article 10(1) of the former Restriction of Special Taxation Act

2014du7442 Revocation of revocation of the imposition of corporate tax

AAA life insurance company

Head of Yeongdeungpo Tax Office

Seoul High Court Decision 2013Nu20235 Decided April 24, 2014

The appeal is dismissed.

The costs of appeal are assessed against the defendant.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but the grounds of appeal by the appellant are not included in the grounds provided by each subparagraph of Article 4(1) of the Act on Special Cases Concerning the Procedure for Appeal, and the appeal is dismissed pursuant to Article 5 of the same Act. It is so decided as per Disposition by the assent of all participating Justices