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(영문) 서울행정법원 2013.11.14 2013구합5401
종합소득세등부과처분취소
Text

1. On January 16, 2012, the head of the Ansan Tax Office’s “amount of imposition disposition” in attached Table 1. attached Table 4, which was against the Plaintiff C.

Reasons

1. Details of the disposition;

A. The Plaintiffs’ status 1) Plaintiff A centered on D is the wife, and Plaintiff B and Plaintiff A’s children are D and Plaintiff A’s children. 2) The E Co., Ltd. (hereinafter “F Co., Ltd.”) was changed from “E”) to “E” on November 20, 2010,” and the E (hereinafter “E”) was established on December 30, 1986, and a domestic corporation specialized in manufacturing and selling the livers system, which is the core location of plastic withdrawal.

The shareholders and equity shares of E as of the end of 2010 are as follows:

E Shareholders E’s Equity Ratio (%) D 58 Plaintiff A 17.41 Plaintiff B 18.59 Plaintiff C 100 3) D, etc. around October 2003 G (hereinafter “G”) in Hong Kong around October 2003.

B. On July 7, 2005, G established H (hereinafter “H”) for the purpose of owning G’s shares in Hong Kong and China. The shareholders of the said company were as follows, and the said company was liquidated around July 201, 201.

H The share ratio (%) D 25,500 A 4,500 B 10,00 B 10,000 B 20,000 C 10,000 C 10,000 20.00 20,000 20,000) D, Plaintiff A, and B transferred G shares to H on August 25, 2005 (D 3.66 million shares, Plaintiff A420, Plaintiff B220,00 shares). On the same day, Plaintiff B transferred 60,00 shares to Plaintiff C (hereinafter “20, 2000 shares”), indirectly, the Plaintiffs transferred G shares owned to Plaintiff C on August 29, 2008 (hereinafter “Plaintiff A120, Plaintiff B, 60,000 shares,” and the Plaintiffs did not own shares directly through Plaintiff C 60,000 shares.

(‘Indirect’ means that the proportion is calculated by multiplying the H’s shares ratio and the shares ratio of G issued shares. G shareholders’ change: D 3,060,000 directly and indirectly (%) - 2,907,000 - 3,029,400 - 540,000 A 540,000 - 120,000 - 513,000 - 534,600 - 534,600 - 2,340,000 - 2,340,600 - 60,000 - 60,000

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