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(영문) 수원지방법원 2016.01.06 2014구합57394
법인세 부과처분 등 취소청구
Text

1.(a)

On April 8, 2011, the director of the Korea Tax Office rendered on April 2008 against the Plaintiff Punooa Korea Co., Ltd.

Reasons

1. Details of the disposition;

A. The Plaintiffs’ relationship 1) Plaintiff PRI is Plaintiff PRI Co., Ltd. (former career siren Co., Ltd. from September 2008 to the current trade name on and around September 2008; hereinafter “Plaintiff PRI”).

D) On May 9, 2006, JBIC Co., Ltd. (hereinafter referred to as “JBIC”) and on May 9, 2006

) Plaintiff PRK Co., Ltd. (hereinafter “Plaintiff PRK”) that comprehensively acquired the business of Plaintiff PRK.

(2) On February 2000, Plaintiff PRK entered into a joint security settlement service contract with the following contents. On April 14, 2006, Plaintiff PRK succeeded to the above contractual status of JBIC by comprehensively taking over all the business related to the import and sale of the Puhoe and sirens products from JBIC.

Article 1 (General Provisions) JBIC and Plaintiff PTRI both companies shall use part of the other party's services, determine and settle the amount of share for indirect expenses incurred by the other party's company, and each company shall bear the direct expenses, the intention of which is clear, in accordance with the principle of response to profit-making expenses.

Article 2 (Definition of Expenses and Period subject to Settlement) Among sales expenses and general management expenses paid during each fiscal period, the amount of indirect expenses needed to use part of the other party services and to distribute them to the other party company as a result, and the period subject to settlement shall be in accordance with the fiscal year of both companies

However, in the case of the first year of the transfer of the assets and liabilities of JBIC by the Plaintiff PRK, the two parties shall settle the accounts for each period of reasonable consultation.

Article 3 (Accounting Standards Data) The two companies shall distribute the sales expenses and general management expenses of the financial statements audited by an external auditor after the end of each fiscal year based on the amount and details thereof.

Article 4 (Standards for Distribution of Common Expenses) The amount of sales expenses and general management expenses as of the end of each fiscal year shall be settled.

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