Seoul High Court 201Nu3502 (2012.05.10)

early 209west2619 ( November 10, 2009)

(C) the terms of the stock transfer agreement are deemed to have been effectively transferred.

(Summary of the Judgment of the Supreme Court) It is recognized that the ownership was transferred by transferring its ownership in accordance with the contents of a stock transfer contract and that the imposition of transfer income tax and gift tax on low-price transfer is unconstitutional due to double taxation

Article 101 of the Income Tax Act

2012Du12785 Revocation of Disposition of Imposing capital gains tax

XX

The Director of Gangnam District Office

Seoul High Court Decision 2011Nu3502 Decided May 10, 2012

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

While examining the grounds of appeal in comparison with the records of this case and the judgment of the court below, the ground of appeal on the grounds of appeal is not deemed to have been rejected or not.

Therefore, the appeal is dismissed. It is so decided as per Disposition by the assent of all participating Justices.

Reference materials.

If the grounds for final appeal are not included in the grounds of appeal that make it appropriate for the court of final appeal to become a legal trial, such as matters concerning significant violation of Acts and subordinate statutes, etc., the system of final appeal will not continue to proceed with the deliberation on the merits of the grounds for final appeal, but will not proceed with the deliberation on the merits of the grounds for final