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| TITLE | Supreme Court en banc Decision 2010Du17564 Decided November 22, 2012【Revocation of Disposition Denying Claim for Correction of Corporate Tax】 [full Text] |
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| Summary | |
| Where the market price of a stock is no less than the par value and no more than the issue price in a debt-equity swap, whether Article 15(1) of the former Enforcement Decree of Corporate Tax Act (amended by Presidential Decree No.18174, Dec. 30, 2003) defining “surplus over par value” of Article 17 subparag. 1 of the former Corporate Tax Act as the amount deducting par value from market value is invalid against the principle of no taxation without the law (affirmative) | |


