The costs of appeal are assessed against the Plaintiff.

The principle of substantial taxation under Article 14(1) of the former Framework Act on National Taxes (amended by Act No. 9911, Jan. 1, 2010) refers to a person to whom income, profit, property, transaction, etc., belongs, if there is a separate person to whom such income, profit, property, or transaction, etc., belongs, not the nominal owner on the ground of form or appearance, but the person to whom such income, etc., belongs, is to be the person to whom such property, and the nominal owner is not the person to whom such property, actually controls and manages such property through the control, etc. over the nominal owner, and the disparity between the nominal owner and the real owner is derived from the purpose of tax avoidance, the income on the property shall be deemed to have been reverted to the person to whom the property is substantially controlled, and such principle applies, barring any special provision to exclude this from the interpretation and application of the tax treaty having the same effect as the Act (see, e.g., Supreme Court Decision 2010Du25466, Oct. 25, 2012>