Seoul High Court-2017-Nu-43205 (No. 19, 2018)

(C) If financial statements, etc. are received voluntarily, it shall not be deemed a tax investigation, and when calculating an additional tax for unfaithful payment, the additional tax for an indefinite payment shall be deemed the tax amount paid.

It shall not be deemed an illegal tax investigation that voluntarily receives and examines the financial statements for the year to which the period of investigation exceeds the period of investigation, and an inorganic penalty tax paid by a person subject to double-entry bookkeeping when filing an income tax return by estimation shall be deducted from the amount of tax paid in calculating the additional tax when correcting the amount of tax in accordance with the account books,

Article 81-9 of the Framework Act on National Taxes to restrict the extension of the scope of tax audits and to impose additional taxes on payment and refund in good faith

2018Du36295 Revocation of Disposition of Imposing global income tax, etc.

-Appellee

1.2 Habal et al.

-Appellant

Head of the District Tax Office

Seoul High Court Decision 2017Nu43205 Decided January 19, 2018

on 15, 2018

All appeals are dismissed.

Costs of appeal shall be borne by each party.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the appellant's grounds of appeal fall under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal and therefore, all of the appeals are dismissed pursuant to Article 5 of the above Act. It is so decided as per Disposition by