Seoul Administrative Court 2012Guhap35733 (22 August 2013)

Research and development expenses re-entrusted shall be subject to tax credit regardless of whether the re-entrusted enterprise has a dedicated department.

Research and development expenses corresponding to the portion re-entrusted by the trustee company are subject to tax credit, and it is reasonable to view that research and development expenses are subject to tax credit even if the trustee company does not hold the research institution

Article 10 of the Restriction of Special Taxation Act, Article 9 of the Enforcement Decree of the Restriction of Special Taxation Act

2013Nu26394 Revocation of Disposition of Corporate Tax Imposition

AA Life Insurance Corporation

Head of the tax office;

Seoul Administrative Court Decision 2012Guhap35733 decided August 22, 2013

January 8, 2014

January 29, 2014

1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

The judgment of the first instance shall be revoked. The defendant's disposition of imposition of the OOOO on April 1, 2005 against the plaintiff on March 1, 201 to March 31, 2006 shall be revoked.

The reasoning of this court's decision is the same as that of the court of first instance, and thus, it is cited in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

Therefore, the plaintiff's claim of this case is justified, and the judgment of the court of first instance is just, and the defendant's appeal is dismissed. It is so decided as per Disposition.