Busan High Court-2016-Nu10612 (Law No. 16, 09.07)

Article 32(5)2 of the Restriction of Special Taxation Act amended on January 1, 2013 applies to "from the date of disposal of stocks after January 1, 2013".

(C) Article 32(5)2 of the Restriction of Special Taxation Act (amended by Act No. 11614, Jan. 1, 2013) applies to cases where Article 32(5)2 of the Restriction of Special Taxation Act (amended by Act No. 11614, Jan. 1, 2013).

Article 32 of the Restriction of Special Taxation Act (Carryover Taxation of Transfer Income Tax for Conversion into Corporation)

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but the argument on the grounds of appeal by the appellant falls under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal, and therefore, the appeal is dismissed under Article 5 of the same Act. It is so decided as