A | 北京时间1月9日，韩国最高法院周三裁定，三星电子与一家爱尔兰导管公司达成专利许可协议，以利用韩国爱尔兰税收协议中的特别豁免条款逃税并支付15亿韩元（134万美元）的公司税。导管公司的成立通常是为了逃避或减少税收，转移或积累利润。韩国最高法院星期三对三星做出裁决，结束了长达五年的诉讼。
B | 三星在2013年以原告的身份向韩国最高法院提出上诉，质疑韩国税务机关让三星承担706亿韩元的公司税的决定。 As excitement steadily builds around Jailer 2, a new piece of casting buzz has begun doing the rounds in Chennai film circles. According to industry sources, Nora Fatehi is likely to appear in a major song sequence alongside Rajinikanth in the much-anticipated sequel. While there has been no official confirmation yet, the chatter has grown persistent enough to suggest that the collaboration is more than mere speculation.Jailer, directed by Nelson, became a phenomenon upon release, fuelled by Rajinikanth’s towering screen presence and Anirudh Ravichander’s chart topping music. The sequel is expected to expand that universe while raising the bar in terms of scale and spectacle. The possible inclusion of Nora Fatehi appears to be part of that larger ambition. A song built for scale and swagger Sources suggest that Nora is currently in Chennai shooting an outdoor dance number designed as a full-fledged visual spectacle. The track is said to be composed by Anirudh Ravichander, whose association with Rajinikanth films has consistently resulted in viral hits and mass appeal anthems. What stands out is the reported duration of the shoot. Nora is said to be filming for nearly eight days alongside Rajinikanth, a detail that hints at the scale and importance of the sequence within the film. In Rajinikanth’s cinema, songs often serve a narrative and myth building purpose rather than functioning as standalone interludes. Whether it was style driven introductions or moments of playful dominance, music has long been a tool to reinforce his screen persona. Placing Nora Fatehi within this framework suggests a carefully curated sequence that blends his trademark charisma with contemporary dance energy.Those close to the project indicate that the song is expected to be upbeat and rooted in a South Indian musical sensibility, even as it accommodates Nora’s global dance appeal. Rather than a fleeting appearance, the number is reportedly being designed as one of the film’s standout moments, with visual ambition to match its musical punch. A crossover that reflects changing cinema Nora Fatehi’s possible casting also reflects the increasingly porous boundaries between film industries. Over the past few years, she has emerged as a recognisable global pop culture figure, with her music videos and performances travelling far beyond Indian cinema circuits. Her recent run of viral songs and international collaborations has positioned her as a performer whose presence instantly expands a film’s reach across demographics and geographies.Pairing her with Rajinikanth is not just about novelty. It represents a meeting of two distinct kinds of star power. Rajinikanth embodies decades of mass appeal, cultural memory, and cinematic mythology. Nora brings with her a modern, internet savvy energy that resonates strongly with younger audiences. If the reports are accurate, Jailer 2 may be attempting to harness this contrast to create a musical moment that feels both rooted and contemporary. Directed by Nelson, who is known for blending irreverent humour with stylised action, Jailer 2 carries significant expectations after the first film’s success. The original featured a carefully assembled ensemble and music that became a cultural talking point. A high profile song featuring Nora Fatehi could be one way the sequel signals its intent to go bigger without losing its core tone.For now, the Rajinikanth and Nora Fatehi collaboration remains an industry buzz rather than confirmed fact. But if it does materialise, it is likely to become one of the most discussed elements of Jailer 2, long before the film reaches theatres. Also Read: Rajinikanth Celebrates Birthday With A Surprise On Jailer 2 Set。然而，韩国最高法院仅部分支持上诉法院的判决，即三星只应承担15亿韩元的企业税。早些时候，上诉法院裁定三星应承担所有706亿韩元的公司税。韩国最高法院认为应该取消海外专利税。2010年，三星与美国全球知识产权管理公司IntelligentVentures签订了专利许可合同，支付后者3.7亿美元。高志敏表示，其爱尔兰子公司四一是协议的一方，因此该协议应享受韩国爱尔兰税务协议中的公司免税条款。
C | 根据韩美税制，被许可方应支付15%的许可费作为公司税。然而，韩国税务官员表示，IvIl只是一家避税公司，因此他们向三星签发了一份706亿韩元的税单。尽管下级法院接受了三星的反驳，但上诉法院推翻了判决，并裁定三星对所有税收负有责任。
Current article:http://www.zhouangnaoguangsundianzhenmou.cfd/list_72l89s/u8cc0it.docx
Published on:17:00:08
