Seoul High Court-2015-Nu-33693 (Law No. 21, 2016)

2012west 3629 (2014.03.09)

(A) The tax authority must prove the acquisition value which is the actual transaction value.

In principle, the tax authority must prove the acquisition price, which is the actual transaction price, even if the transfer price is based on the actual transaction price and the actual transaction price cannot be confirmed, and if it is not proven, the tax authority should only make the estimation based on the conversion price, etc.

Article 97 of the Income Tax Act as necessary expenses

Article 163 of the Enforcement Decree of the Income Tax Act