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1. The Defendant:
A. With respect to Plaintiff A, additional tax of KRW 2,137,256,370 for global income tax for the year 2005 reverted to May 16, 2016.
Reasons
1. Details of the disposition;
A. The Plaintiffs, as married couple, have two children (C and D) under the chain.
The Plaintiffs begin with their business in China since 1994, and establish and operate eight corporations, including E-Limited Corporation (hereinafter “instant corporations”).
B. From 2005 to 2008, the Plaintiffs were transferred the total amount of KRW 12,615,280,081 (hereinafter “instant amount”) from China by means of an alternative remittance via a foreign exchange hub (i.e., a one-time transshipment method).
C. From September 25, 2009 to December 4, 2009, the director of the Seoul Regional Tax Office conducted a tax investigation with respect to the Plaintiffs (hereinafter “tax investigation”). At the time, when the Plaintiffs submitted the account books of the instant corporation whose key amount, etc. is included in the provisional payment against the Plaintiffs (hereinafter “instant account books”), the key amount was not separately exempted from taxation because they asserted that the key amount was the debts to the instant corporation. D) After that, the director of the Seoul Regional Tax Office verified that the Plaintiffs’ tax investigation conducted on the Plaintiffs from July 6, 2016 to September 7, 2016 (hereinafter “individual integrated investigation”) did not refund the key amount to the instant corporation, and determined that the key amount was “dividend income” acquired by the Plaintiffs from the instant corporation.
The director of the Seoul Regional Tax Office, from 2004 to 2008, notified the Defendant of the taxation data by deeming that the Plaintiff did not pay the comprehensive income tax on the dividend income equivalent to the key amount from 2005 to 2008.
The notified tax amount (including additional tax) of the omission on the date of the imposition of the year to which classification belongs, Plaintiff A (including additional tax) 2,714,964,978,978 won 2,137,256,370 won on May 16, 2016, 2006, KRW 1,948,378,340 won on October 4, 2016, 2006, KRW 3,811,925,135 won, KRW 3,083,724, 110 won on 208,682,77, KRW 280, KRW 1,269,618,390 on October 4, 2016.