beta
Text
1. The defendant on July 1, 2010
Plaintiff
A 211,668,680 won for the year 2008 and 272,095,010 won for the year 2009.
Reasons
1. Details of the disposition;
A. As a permanent resident of Singapore, Plaintiff A worked as the representative director of Singapore Co., Ltd. (hereinafter “C”), a domestic corporation (hereinafter “C”), which is a domestic corporation operating hotel Internet and VOD services, etc. from April 1995 to December 2, 200; from May 199 to May 200, Plaintiff A worked as a general manager of the operation of the headquarters of the Republic of Singapore (COO, White EFO) located in the U.S. D company, the parent company; from May 2 to December 2007, 200, Plaintiff A worked as the representative director of the D company and its business and assets comprehensively; from February 2, 2008 to May 2, 2007, Plaintiff A worked as the representative director of the Singapore company (hereinafter “E”).
Plaintiff
B is a domestic resident who has invested in G companies (hereinafter referred to as “G”) as follows:
B. G is a special purpose company established in Malaysia for the investment, management, etc. of E, etc. on May 2000, in which Plaintiff A owns 83% shares, and Plaintiff B owns 17% shares, respectively.
C. The director of the Seoul Regional Tax Office, as a result of conducting an integrated investigation of corporate tax against C engaged in hotel Internet and VD service business, notified the director of the regional tax office of taxation data to impose tax on the identified facts as follows.
Accordingly, the head of the tax office of the regional tax office imposed corporate tax on C in the business year of 2005 or 2008, and the G established in D, a tax avoidance area, is merely a conduit company with no economic substance, and thus, the amount included in C’s gross income was deemed to have been released from the company, and accordingly disposed of as bonus, and notified the changes in the income amount.
(1) Around September 2007, G waives the call option to obtain 20% of the shares issued by E to G, a foreign related party, and by having G exercise it at a low price, thereby allocating the profits equivalent to the difference in the market value to G.