logobeta
본 영문본은 리걸엔진의 AI 번역 엔진으로 번역되었습니다. 수정이 필요한 부분이 있는 경우 피드백 부탁드립니다.
텍스트 조절
arrow
arrow
(영문) 서울고등법원 2014.01.29 2013누12593
법인세부과처분등취소
Text

1. The part of the judgment of the court of first instance against the plaintiff ordering revocation shall be revoked.

Defendant on March 2, 2010.

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 expenses for business activities, entertainment expenses, sales promotion expenses, publicity expenses, etc., which are alleged as ① payment of cash (hereinafter “cash payment”) or ② payment of merchandise coupons, etc. (hereinafter “payment of merchandise coupons”) or ③ payment of meal expenses, etc. on behalf of the Plaintiff (hereinafter “payment of food expenses”) in order to promote the sales of drugs and promote the collection of sales proceeds as follows.

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 to impose corporate tax of 389,294,640 won on the Plaintiff in March 2, 2006, corporate tax of 12,249,593,270 won, corporate tax of 2007, corporate tax of 7,962,529,400 won, and to impose corporate tax of 208,277,718,183 won in total (17,95,39,39,594 won in 2006, and 27,516,390,639 won in 207, 208, 22765,987,905 won in 207, and 68,277,987,905 won in 206).

On April 21, 2010, the Plaintiff appealed and filed a petition with the Tax Tribunal for a trial on April 21, 201. The Tax Tribunal rendered each disposition on September 21, 201, regarding the payment of merchandise coupons as entertainment expenses, and revised the tax base and tax amount by deeming the payment of merchandise coupons as entertainment expenses for the pertinent business year.

arrow