Busan High Court Decision 2013Nu901 (Law No. 13.24, 2013)

Cho High Court Decision 201J 0898 ( October 25, 2012)

(D) Since the instant money that the Plaintiff remitted to the Hong Kong local subsidiary is a loan, the amount equivalent to the interest should be included in the calculation of the amount of interest.

(C) In light of the above legal principles, it is reasonable to view that the Plaintiff’s transfer of the instant money to E companies, Hong Kong, as the Plaintiff’s transfer of the instant money to E companies, is a direct overseas investment through lending of money to foreign corporations. Therefore, the interest income on the instant money should be included in the corporation’s

Article 28 (Non-Inclusion of Interest Paid in Loss)

2013du17824 Disposition of revocation of revocation of corporate tax rectification

AA enterprise, Inc.

Head of Seogsan Tax Office

Busan High Court Decision 2013Nu901 Decided July 24, 2013

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The judgment of the court below and the appellate brief all of the records of this case, but the appellant's ground of appeal is not included in the grounds provided by each subparagraph of Article 4 (1) of the Act on Special Cases Concerning the Procedure of Appeal or it is recognized that there is no reason. Thus, the appeal is dismissed under Article 5 of the same Act. It is so decided as per Disposition by