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(영문) 서울행정법원 2016.08.19 2014구합65967
법인세부과처분취소
Text

1. Each of the imposition of additional tax as stated in the separate disposition list against the Plaintiffs is stated in paragraph (2).

Reasons

1. Details of the disposition;

A. The Plaintiffs (1) concluded a current account with the issuer of CPs, (2) the issuance of CPs, and (3) the payment of CP bills by the Plaintiffs (1) and the issuance of CPs to the issuer of CPs. 2) The issuer of CPs at discount by the securities company, etc. (hereinafter “the discount”).

3) When the maturity date of the corporate bills arrives, the bearer of the corporate bills shall make another bank that deals with the undeposited corporate bills with the Korea Securities Depository (hereinafter “Presentation Bank”).

(B) The Plaintiffs suggested to pay the amount of the face value of the corporate bills to the presenting bank, in the absence of any error after confirming the necessary form and form stated in the corporate bills proposed through a clearing house, and then withdrawing the amount from the current account of the issuing company of the corporate bills and paying the face value of the corporate bills to the presenting bank. (b) The Plaintiffs did not withhold the tax on interest income equivalent to the amount of the discounted value of the corporate bills when paying the amount of the corporate bills as above. The corporate bills and discounted amounts of the corporate bills of this case were not withheld. The said

(2) The sum paid and discounted amount of the bill of exchange (hereinafter “instant discount amount”).

The details of the meeting are as listed in the following table 1:

In Table 1, the Bank of Korea shall, in 2010.3,812,50,00,000 won 22,107,678,428,421,170 won in an overseas exchange bank, which has agreed to operate a savings bank of 2010,538,100,100,030,000,000, 9,031,521,170 won in a bank of 2010,30,000,000,000, 6,020,268,268,165 won in a bank of 2010,90,50,50,000, 30,50,50,000, 306,30,50,341,00,000, 20,000, 100,000,105,363,207,5,207,36,27,27,308.

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