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(영문) 서울행정법원 2013.04.12 2011구합43263
법인세부과처분등취소
Text

1. All of the plaintiff's claims are dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Reasons

1. Details of the disposition;

A. The Plaintiff is a company established around December 199 as the main business of manufacturing and selling complete medicine, such as B (B), C (B), D (B), E (B (B), etc.

B. The Plaintiff filed corporate tax for the pertinent business year by appropriating the following expenses (hereinafter “instant expenses”) for business expenses, entertainment expenses, sales promotion expenses, publicity expenses, etc.: (i) payment of cash (hereinafter “cash payment”) to a doctor, pharmacist, etc.; (ii) payment of merchandise coupons, etc. (hereinafter “money coupon payment”) or (iii) payment of meal expenses, etc. on behalf of the Plaintiff (hereinafter “payment on behalf of the Plaintiff”); and (ii) payment on behalf of the Plaintiff for food expenses, etc.; and (iii) payment on behalf of the Plaintiff was included in business expenses, entertainment expenses, sales promotion expenses, public relations expenses, etc.

Classification 12,502,946,097, 237,639, 639, 389, 676, 865,950 38,417,451, 492, 393, 493, 497, 11,278, 2751, 250 13,089,1222,000, 29, 260, 266, 747 of cash payments for the year 2007, 208, 12,778,563,63,826, 35, 408, 787, 3784, 375, 3787, 3784, 375, 3787, 387, 1987, 197, 197, 197

C. On March 2, 2010, the Defendant issued a disposition imposing KRW 12,249,59,593,718,183 (17,95,39,594, KRW 275,594, KRW 207, KRW 275,987,95, KRW 207, KRW 389,596, KRW 6390, KRW 639, KRW 6390, KRW 2006, corporate tax in 2007, corporate tax in 2008, and KRW 7,962,529,540, and KRW 68,277,718, and KRW 183 (in 2006, KRW 17,95, KRW 39,594, KRW 207, KRW 27,516,639, KRW 639, KRW 208, and KRW 905).

On April 21, 2010, the Plaintiff appealed and filed a petition for a trial with the Tax Tribunal. The Tax Tribunal rendered each disposition on September 21, 201, which was rendered on March 21, 201 as entertainment expenses.

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