Seoul High Court-2018-Nu6722 ( October 12, 2019)

Cho Jae-2016-China-1726 (Law No. 23, 2017)

(C) Exchangeable bonds issued are not subject to reduction or exemption of foreign investment tax under the Restriction of Special Taxation Act.

(C) A summary of the Exchangeable Bonds is not included in the ratio of foreign investment under the Restriction of Special Taxation Act, so it cannot be deemed that the stocks or shares subject to reduction or exemption are not included.

Corporate tax reduction or exemption for foreign investment under Article 121-2 of the Restriction of Special Taxation Act.

2019Du41157 Revocation of Disposition of Rejecting Corporate Tax;

Cat○ Co., Ltd.

○ Head of tax office

Seoul High Court Decision 2018Nu67222 Decided April 12, 2019

oly 2019.10

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

Examining the judgment below and the grounds of appeal, since it is apparent that the appellant’s ground of appeal falls under Article 4 of the Act on Special Cases Concerning the Procedure for Appeal, it is dismissed pursuant to Article 5 of the above Act. It is so decided as per Disposition by the assent of all participating Justices.