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(영문) 서울행정법원 2016.10.27 2015구합61771
법인세원천징수처분등취소
Text

1. The Defendant’s disposition of collecting corporate tax and additional tax on June 17, 2014 against the Plaintiff listed in the separate sheet as to the Plaintiff.

Reasons

1. Details of the disposition;

A. The Plaintiff is a non-profit corporation that provides finance necessary for economic cooperation, such as export and import, overseas investment, and overseas resources development, established around July 1976.

B. 1) A Co., Ltd. (hereinafter “A”)

(B) Co., Ltd. (hereinafter “B”).

(C) Co., Ltd. (hereinafter referred to as “C”) and, in total, “Domestic Shipbuildings”.

D and 11 foreign corporations (hereinafter referred to as “foreign vessel owners”) as shown in Table 1 below:

2) Each of the instant shipbuilding contracts that was concluded by the parties to the construction of the vessel (hereinafter “each of the instant shipbuilding contracts”).

C. According to the above 1D 16,200 E 2D 203.12.12. A 36,200,000 F 3D 36,200,000 G 4 H 200 G 2008.3.21, 2008.36,50,000 G 4 H 36,500 G 201.36,000 G 206.21, 200 G 16.0 G 206.3.0, 200 G 16.21, 200 G 206.3.0, 200 G 201, 00 K 6 L 74,50, 2007, 105, 105, 105, 205, 105, 205, 201

C. The Plaintiff entered into a guarantee agreement between the Plaintiff and the foreign vessel owners, as set out in the table 2 below, guaranteed the domestic vessel owners’ obligation to pay advance and interest on the domestic vessel owners.

(hereinafter “each guarantee contract of this case” No. 1) No. 28,960,000 on May 13, 2008: (a) the domestic operator guarantee limit (units: USD) on the date of the contract for the foreign vessel vessel injection; and (b) the interest rate of 1D on July 28, 2008.

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