logobeta
본 영문본은 리걸엔진의 AI 번역 엔진으로 번역되었습니다. 수정이 필요한 부분이 있는 경우 피드백 부탁드립니다.
텍스트 조절
arrow
arrow
(영문) 서울행정법원 2018.07.06 2017구합66886
부가가치세 부과처분 등 취소 청구
Text

1. The defendant's statement of the disposition of this case against the plaintiff (attached Form 1) stated in Paragraph 1 of the claim.

Reasons

Details of the disposition

The Plaintiff is a domestic corporation established on April 14, 2004, and operates a cruise brand, such as Liberia Corporation B (B; hereinafter “cruise headquarters”) E, F, and G, which has its place of business in the United States.

In the United States, C companies (C; hereinafter referred to as “Lendter Head Office”) as U.S. legal entities operate rental car brands, such as H, I, and J, under an international agency contract (INTNATRAL RERESAL REEAL).

The independent business development advisory contract (INDENNES SALS DEES CONT NASSUREALALEEMENT) is a L limited company (L), M, N,O, P, and Q limited company (P), which operates K as a U.S. legal entity (D; hereinafter referred to as "the headquarters").

After entering into a public relations and marketing sales agency contract (PR&MARK GEG GEG GEAL SALS AGREEMNT) with each other (hereinafter referred to as “instant contracts,” referring to each of the above contracts; hereinafter referred to as “foreign corporations,” referred to as “foreign corporations”) with each other; pre-contract and settlement support services related to the services provided domestically by foreign corporations (However, services for this set are not included in pre-contract and settlement services); marketing, public relations, advertising, rental, management consulting, market analysis, travel product planning, etc.; (hereinafter referred to as “market services”); and (c) in return, cruise headquarters and rental-based headquarters were paid part of the service fees paid by domestic customers from the cruise headquarters and rental-based headquarters as service charges; and (d) 150,000,000 U.S. headquarters were paid each month.

The Plaintiff’s key service constitutes “business service, etc.” under Article 11 of the former Value-Added Tax Act (amended by Act No. 11873, Jun. 7, 2013) and Article 26(1)1(b) of the former Enforcement Decree of the Value-Added Tax Act (amended by Presidential Decree No. 23595, Feb. 2, 2012).

arrow