1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. The reasons why the court should explain this part of the disposition are the same as the corresponding part of the judgment of the court of first instance. Thus, this part of the judgment is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

2. Whether the instant disposition is lawful

A. The plaintiff's assertion 1) The plaintiff asserts that the disposition of this case is unlawful primarily for the following reasons and sought revocation of the disposition of this case. (A) The plaintiff falls under the case of a person who resides or works abroad and has an occupation ordinarily required to continue residing abroad for not less than one year, and thus, there is no address in Korea.

B) Even if the Plaintiff constitutes a domestic resident under the Income Tax Act, the Plaintiff constitutes a resident of Katar under the Income Tax Act, and thus, the Plaintiff constitutes “the Convention between the Government of the Republic of Korea of Katar and the Government of Katar for the Avoidance of Double Taxation and the Prevention

(C) The disposition of this case, based on the premise that the plaintiff is a domestic resident under the Income Tax Act, is unlawful, since the plaintiff has a permanent domicile in ktar, is a ktar centered on the plaintiff's significant interest, and since the plaintiff's ordinary domicile is a ktar, the plaintiff is deemed to be a ktar resident under the Korea-Pacific Tax Treaty.

2) The Defendant’s assertion that the instant disposition is lawful on the following grounds. (A) In light of the objective facts of living relationship, including the existence of family members living together in Korea and of assets located in Korea, the Plaintiff constitutes a resident in Korea under the Income Tax Act.

(b) Home Affairs Plaintiff is a resident of Katar under the Income Tax Act.

Even if the plaintiff has a permanent residence in Korea, and is the Republic of Korea centered on the plaintiff's important interest, the plaintiff is within the Republic of Korea under the Korea-Pacific Tax Treaty.