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TITLE 【Syllabus of Latest Opinion】Supreme Court Decision 2015Du39842 Decided July 20, 2018【Revocation of Disposition Denying Petition for Correction】* First draft [full Text]
Summary
Meaning of “repudiation of wrongful calculation” as defined under Article 52 of the former Corporate Tax Act
Standard for determining the existence or absence of economic rationality
Whether the burden of allegation and proof as to “market price” that serves as the standard for applying the repudiation of wrongful calculation lies on the taxation authority (held: affirmative in principle)
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