¡¼Main Issues and Holdings¡½
[1] Principle of interpreting tax laws and regulations and whether an extended interpretation or analogous interpretation is allowed in the interpretation of tax laws and regulations (negative)
[2] In a case where: (a) Company A, which runs payment gateway business, etc., sold documents on which a personal identification number (PIN) is printed, used to trade game currency, to users of online gaming site of its affiliate gaming company through convenience stores across the nation; and (b) the director of the competent tax office imposed a stamp tax on Company B on the ground that the documents constituted a ¡°gift certificate,¡± which is subject to a stamp tax under Article 3(1)8 of the former Stamp Tax Act, the case affirming the lower judgment, which held that the documents do not constitute a ¡°gift certificate¡± subject to a stamp tax
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