意外
三星根据一项专利许可协议被判逃税,并被要求缴纳134万美元的公司税。_我的网站

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Visitors at the Eight Immortals Crossing the Sea scenic area in Yantai, Shandong Province Photo: VCG
I first watched the movie
All Wishes Come True on a sweltering evening in Beijing, the kind of night when the city's heat presses against the windows and the air-conditioning struggles.
The comedy, widely considered one of the best-reviewed Chinese animated features of the 2026 summer season, unspooled its turquoise landscapes and bureaucratic immortals with a lightness that belied the depth of its source material. By the time the credits rolled, I found myself less interested in the characters' KPI struggles than in the place they called home: Penglai - the northern tip of the Shandong Peninsula in East China, where myth and shoreline have shared the same address for more than 1,000 years.
By one Saturday morning, I was on a high-speed train heading east from Beijing, the film still playing in my head. "Don't ask where they came from," the movie's quiet refrain goes, "only where they are going; don't ask about gains or losses, only about right or wrong." It felt like decent travel advice.

A colorful 3D relief depicts the classic Chinese mythological legend 'The Eight Immortals Crossing the Sea' at the Penglai Pavilion scenic area Photo: Xu Liuliu/GT
Fairyland of the mortal worldStepping off the train, Penglai announced itself gradually. The air cooled. The sea appeared, first with shimmering light, then as a broad, restless presence. The average temperature here sits at around 12.5 degrees Celsius for the whole year; winters refuse to freeze the spirit, summers decline to scorch it. Locals call the place "the fairyland of the mortal world," and for once the slogan does not feel like municipal overreach.
I began, as most pilgrims do, at Penglai Pavilion. The Song-dynasty (960-1279) complex rises from a cliff as if the rock itself had decided to become architecture. It is the only seaside member of China's four great ancient towers, and the only one that smells of salt. From its highest platform the Yellow and Bohai Seas meet in a visible seam of color, two blues arguing politely about territory. Legend insists the Eight Immortals gathered here, drank too well, and then crossed the water by their various supernatural means. Standing in the same spot, I could almost hear the clink of chalices.
The pavilion is not a museum of relics so much as a working stage for memory. The hall of Lü Dongbin, one of the Eight Immortals, still receives incense. Stone tablets carved with poems by generations of visitors lean against one another like old friends. In the afternoons, costumed performers - local "NPCs" of the Eight Immortals - wander the stone paths, joking with tourists, offering blessings, occasionally breaking into song. Children chase a character carrying a flower basket; adults pose solemnly beside Tieguai Li. The boundary between screen and shore softens.
One of the locals, who grew up within sight of the pavilion, told me this was the season for haishi - the mirages that have made Penglai famous for centuries. Sea mirages, sea mists, and horizontal fog form the three maritime wonders here, appearing without schedule and vanishing just as quickly. I waited an hour and alas saw only ordinary clouds. Still, the sense of possibility felt sufficiently satisfying.
Across the water lies the Eight Immortals Cross the Sea scenic area, laid out in the shape of a giant gourd - Tieguai Li's preferred vessel. From the highest pavilion the gardens, pavilions, and sculpted figures form a coherent narrative of ascent and departure. Wandering in the area, you will see that the water is calm, the sky the exact shade of celadon used by the animators. It was easy to understand why story-tellers kept returning to this stretch of coast: the landscape itself seems to invite transformation.
Penglai is not only myth. The old water city, China's best-preserved ancient naval base, still holds the outlines of docks where warships once waited. Nearby stand the memorials to Qi Jiguang, the Ming Dynasty (1368-1644) general who defended these shores against Japanese pirates.
The same peninsula that dreams of immortals also remembers the hard work of keeping the sea lanes open. The film's protagonists, for all their comic incompetence, share a stubborn sense of duty toward the human world. Standing among the fortifications, I felt the two strains of the place - celestial and martial - settle into balance.

The iconic memorial archway 'Penglai on Earth' at the Penglai Pavilion Scenic Area in Yantai, Shandong Province Photo: Xu Liuliu/GT
Banquet from seaFood here is another kind of story-telling. At a small restaurant in the city I ordered Penglai noodles, thin and springy, swimming in a broth that tasted of the morning's catch. Later came an "Eight Immortals banquet," each dish inspired by one of the legendary figures: a crisp fish for the crossing, a fragrant wine for the celebration afterward. The wines themselves deserve attention. Penglai sits on the same latitude as some of the world's great vineyards.
In the late afternoon light, the grapes looked almost black, and the air smelled of sea and oak. A glass of local wine, tasted on a terrace overlooking the water, carried a mineral edge that felt like the peninsula distilled.
Evenings belong to the streets. On Xianjie or Immortal Street, lights come on early. Vendors sell souvenirs of the Eight Immortals' magic instruments, small wooden crutches, fans, flower baskets. Musicians play, children run between stalls, and the smell of grilled seafood mixes with the cooler night air. It is ordinary Chinese night-market life, elevated by the knowledge that the stories being sold have been circulating for a millennium.
I spent my last morning climbing Laobeishan or Tianheng Mountain to the precise point where the two seas divide. The water on one side was a deeper yellow, on the other a clearer blue. Tourists took photographs, capturing the magical sight of the water's two different colors.
Penglai is much more than what is portrayed in the movie. The cliffs, the pavilion, the mirages, and the slow accumulation of legend were here long before any animator arrived. Yet the film has done what good popular art sometimes does: it has given a new generation a reason to look again. Walking back down the mountain that morning, I kept thinking of the line about not asking about origins, only about destinations.
Penglai's destiny, it seems, is simply to remain itself - half myth, half working harbor - while the rest of us keep arriving, notebooks open, cameras ready, half expecting to see haishi.
。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。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。

B | 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。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。

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