Text
1. The Defendant shall pay 340,373,400 won to the Plaintiff and 20% per annum from July 9, 2013 to the day of complete payment.
Reasons
In fact, on December 30, 2007, B, etc. donated 100% (C45%, D35%, E20% equity) of outstanding shares to the Defendant Company, where C, D, and E (hereinafter referred to as “C, etc.”) owned 615,793 shares of D, E, etc. (hereinafter referred to as “C, etc.”).
Between March 8, 2010 and April 16, 2010, the Seoul Regional Tax Office conducted a tax investigation on the gift of the said shares, and the Defendant entered into a tax service contract with the Plaintiff on April 6, 2010 with the following contents.
The defendant in the service contract shall enter into a service contract with the following as of April 6, 2010 with respect to the reduction of tax investigations related to the inheritance tax, gift tax, corporate tax, etc. of the Seoul Regional Tax Office on the plaintiff and the commissioning of proxy affairs for tax appeals.
Article 1 (Purpose) The purpose of the service performed by the Plaintiff is to assist the Plaintiff in selecting the Plaintiff as a service provider institution and determining the scope, terms, and conditions of the service in connection with the commission of the Defendant’s tax investigation and proxy business for tax appeals.
Article 2 Services to be rendered to the Defendant by the Plaintiff pursuant to this Agreement and the procedures for performing the services are as follows:
1. The Plaintiff shall, at the request of the Defendant, provide the Seoul regional tax office with the authority to conduct a tax audit conducted by the Defendant.
2. The Plaintiff shall, at the Defendant’s request, provide an agency for tax appeals in cases where a gift tax is collected at the Seoul Regional Tax Office’s tax audit conducted by the Defendant.
Article 6 Remuneration
1. The details of the remuneration for the plaintiff and other terms and conditions of the payment are as follows:
The remuneration for this service provided by the Plaintiff against the Defendant shall be the advance payment of the two million Won Won (Won 20,000,000).
this commencement shall be deemed to have been claimed on the date of conclusion.
2. In addition to the retainers under the above paragraph (1), the Plaintiff did not impose gift tax on the following matters at the stage of tax investigation, or did not appeal taxes.