Seoul High Court-2017-Nu71569 (Law No. 25, 2018)

(A) The amount equivalent to the transfer price of the instant shares cannot be deemed as the appraisal loss of the assets included in deductible expenses.

(C) The retirement allowance provision of the instant case does not constitute a retirement benefit provision of the Enforcement Decree of the Corporate Tax Act, since the retirement benefit provision of the instant case appears to have been established as a temporary means for allocating the corporation’s funds to a specific officer by lending the form of retirement benefit; thus, it does not constitute a retirement benefit provision of executive officers under the Enforcement Decree of the Corporate Tax Act.

Article 19-2 (Non-Inclusion of Bad Debts in Deductible Expenses)

Article 44 of the Enforcement Decree of the Corporate Tax Act

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

While examining the grounds of appeal in comparison with the records of this case and the judgment of the court below, the main text of the grounds of appeal is determined not to include or not to accept the grounds prescribed in the subparagraphs of Article 4(1) of the Act on Special Cases Concerning the

Therefore, the appeal is dismissed. It is so decided as per Disposition by the assent of all participating Justices.