A Imprisonment for three years, Defendant B and C, respectively, and Defendant D Co., Ltd. shall be punished by a fine of 50,000.

Defendant A is the representative director of K Co., Ltd. (former D Co., Ltd.; hereinafter referred to as “K”) established for the purpose of leasing real estate, and exporting and importing real estate in Gangnam-gu Seoul J, and is engaged in the overall operation and fund management of the company, and Defendant B and C are certified public accountants belonging to each L Accounting Corporation.

1. On May 2008, Defendant A: (a) was anticipated to impose a tax amount exceeding KRW 40 billion on the gift of “M building” equivalent to KRW 10,000,000,000 on the land owned by K, which is a building owned by K, and KRW 40,000,000,000, which is a building owned by K, if the gift is to be donated to his/her children; and (b) requested O, the president of NN branch, a corporation engaging in real estate development business, to prepare a tax reduction plan.

around July 208 to August 8, 2008, at the Q Accounting Corporation's office located in Seoul PP building, Defendant B, a certified public accountant, sought measures to prepare for tax evasion and tax investigation with Defendant B and C. On the other hand, the Hong Kong corporation, the representative of R R (hereinafter "R") acting for the establishment and management of Pucom, and consultation on the opening of a Pucom establishment and an account in Hong Kong necessary for the implementation of the plan for tax reduction, etc. from September 2008 to September 2008, Defendant A planned a plan to donate the above building to his children without paying taxes (hereinafter referred to as "commercial franchise").

The specific content is that if the gift tax base exceeds KRW 3 billion in the Republic of Korea, about 50% tax should be paid for the excess portion, but Hong Kong does not impose income tax or gift tax on stock transfer. K obtained a loan of KRW 30 billion from a bank as security for the above building from the bank and made an investment in the Chinese Steel company through Hong Kong Pucomer in Hong Kong, but it is the most likely that K would have made an investment in the above building after several months, and it collects KRW 4.5 billion out of the above funds as settlement money.