Seoul Administrative Court-2016-Gu Partnership-69437 ( August 25, 2017)

Whether the amount to be compensated for the exercise of stock option before the date of the agreement shall be included in deductible expenses.

Stock-based compensation costs fall under personnel expenses and must be included in deductible expenses, and the requirements of Article 19 subparagraph 19 of the Enforcement Decree of the Corporate Tax Act are also satisfied.

Article 19 subparag. 19 of the Enforcement Decree of the Corporate Tax Act; Article 19 subparag. 3 of the Enforcement Decree

2017Nu71590 Revocation of revocation of revocation of correction

○○○○○○○○ Bank

○ Head of tax office

December 14, 2017

January 11, 2018

1. The defendant's appeal is dismissed.

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

1. Purport of claim

The defendant's rejection of correction of corporate tax of 0,000,000,000,000,000,000,000,000 for the business year of 2011, and 0,000,000,000,000 for the business year of 2012 shall be revoked.

2. Purport of appeal

The judgment of the first instance is revoked. The plaintiff's claim is dismissed.

1. Quotation of judgment of the first instance;

The reasoning of the judgment of the court is the same as that of the judgment of the court of first instance, and thus, it shall be quoted by Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the

2. Conclusion

Since the judgment of the first instance is justifiable, the defendant's appeal is dismissed as it is groundless.