Supreme Court Decision 2016Du38112 Decided September 24, 2020 【Revocation of Disposition Imposing Global Income Tax, etc.】

Whether the purpose of the secondary tax liability of a corporation and the requirements for application thereof stipulated in Article 40 of the Framework Act on National Taxes ought to be strictly construed (affirmative)

Where proceedings for the disposition on default including seizure, etc. in accordance with the National Tax Collection Act are restricted for reasons other than the restriction of transfer pursuant to Acts, etc. with regard to owned stocks, etc. of investors, whether the case corresponds to “where the transfer of owned stocks, etc. of investors are restricted pursuant to Acts” stipulated in Article 40(1)2 of the Framework Act on National Taxes (negative)