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1. On January 2, 2013, the Defendant imposed corporate tax of KRW 440,514,610 (including additional tax) on the Plaintiff for the business year 2008.
Reasons
1. Details of the disposition;
A. 1) B Co., Ltd. (former Trade Name: C; hereinafter “B”).
(2) On October 6, 2003, D, a representative director of the said company, was a major shareholder of the said company. 2) On May 28, 2008, D, a company that runs the wholesale business of drugs, etc., was established on March 7, 191, and settled on September 30, 201, and on May 2, 201, D, the actual representative director and the controlling shareholder of the said company.
B. From October 8, 2012 to November 23, 2012, the director of the Seoul Regional Tax Office: (a) conducted an investigation into corporate tax integration with the Plaintiff (hereinafter referred to as “instant tax investigation”); (b) as a result, the Plaintiff calculated the processed sales of KRW 3,233,584,127 from 208 to 2010; and (c) received the said amount from B (hereinafter referred to as “the above KRW 3,233,584,127”) by paying the processed sales of KRW 3,23,58,127 from the said processed sales until the said processed sales period; (d) 1,148,568,70 from the said processed sales period (hereinafter referred to as “the above processed sales period”); and (e) 2, 209, 280, 268, 286, 208, 286, 208, 208.