2. The costs of appeal shall be borne by the Defendant.

On January 11, 2012, the Defendant: (a) filed a request for revocation of the imposition of each gift tax (total amount of tax) stated in attached Table 1, attached Table 1, attached Table 1, which the Defendant made against the Plaintiff on January 13, 2012; (b) the imposition of each global income tax (total amount of tax) listed in attached Table 1, attached Table 1, which the Defendant made against the Plaintiff on January 13, 2012; (b) the imposition of global income tax for the year 2006; and (c) the imposition of the global income tax for the year 2007; and (d) the revocation of the imposition of the global income tax for the year 207, which exceeds the KRW O on January 11, 2012 (the Plaintiff initially filed a request for revocation of the imposition of the capital gains tax for the Plaintiff on January 11, 2015). However, the Defendant made a request for the reduction of the claim from the date of pleading.

2. Purport of appeal

The part against the defendant in the judgment of the first instance shall be revoked. The plaintiff's claim corresponding to the above revocation shall be dismissed.

The Plaintiff filed a claim for the revocation of the portion exceeding the OO won among the imposition of each gift tax as set forth in attached Table 1, the imposition of each global income tax as set out in Paragraph 1, the imposition of each global income tax as set out in Paragraph 2, the imposition of each global income tax (each global income tax as set forth in 2008, 2009, and 2010), the imposition of the OO tax as global income for 2006, the imposition of the OO tax as global income for 2007, and the imposition of the OO tax as global income for 207. The judgment of the first instance court accepted the Plaintiff’s claim on each of the imposition of gift tax as well as the imposition of each global income tax for 208, 209, and 2010, and dismissed the remainder of the Plaintiff’s claim. The Plaintiff

Therefore, the scope of this court's adjudication is limited to the imposition of each gift tax stated in attached Table 1, the imposition of each comprehensive disposition described in Paragraph 1, and the imposition of each global income tax for the year 2008, 2009, and 2010.

2. Details of the disposition;

A. Status of the Plaintiff and its related company

1)Y Co., Ltd. (hereinafter referred to as “YY”) is a domestic corporation that manufactures and sells a liver system, the core location of plastic withdrawal scheme, in a specialized manner. As of the end of 2010, 58% out of issued stocks, as of the end of 2010, the Plaintiff owns the largestB, ChildCC, and UDD, the spouse of which are 42%.

2) The Plaintiff and the Y established an overseas corporation performing the functions of a manufacturing company, selling company, or holding company in China, Hong Kong, Europe, the United States, etc. for the overseas production, sales, etc. of the liver system, and the corporations involved in the instant case are as follows:

(a) AO(hereinafter referred to as "AO") is a corporation established in Hong Kong in October 2003 and Y1 affiliated companies in Hong Kong and China; (b) ABO(hereinafter referred to as "AB") is a corporation established in Hong Kong and China; (c) on July 7, 2005, the Plaintiff and their family members have been dissolved and liquidated at July 201; (c) the shareholders of Hong Kong hold 80% of its shares in 9, as a corporation established in Hong Kong in 2002; (d) the shareholders of YO (hereinafter referred to as "YCC"); (e) the shareholders of 90% of their shares in 200 and 9% of its shares in 200 and 9% of its outstanding shares in 200, and 9% of its shares in 19, its affiliated companies (hereinafter referred to as "YOE"); and (e) the 90% of its outstanding shares in 201, its affiliate companies in China.

1) Around November 2011, the director of the Seoul Regional Tax Office conducted a tax investigation with respect to the Plaintiff, etc.: ① AA received dividend from its subsidiary and did not distribute it to the Plaintiff, etc. who is a de facto shareholder; ② In fact, with respect to loans from E, the Plaintiff was paid special bonuses from YCC; ③ Foreign Wage OOE and OOOE paid received from Japan and the United States were omitted; and ③ notified the Defendant of the pertinent taxation data by deeming that the taxation data was omitted.

2) Accordingly, on January 11, 2012, the Defendant reported that the global income had been generated to the Plaintiff as follows pursuant to Article 17 of the former Adjustment of International Taxes Act (hereinafter referred to as the “International Tax Adjustment Act”), and notified the Plaintiff of the comprehensive income tax for the year 2008, the year 2009, and the year 2010, respectively (hereinafter referred to as the “instant global income tax imposition disposition”).

C. Gift tax related

1) At the time of establishment on July 7, 2005, AB issued a total of 50,000 shares as of July 7, 2005. The Plaintiff respectively acquired OO shares (51%) among the issued shares, UCC, UDD shares (20 per share ratio), and the highest BB shares (9 per share ratio).

2) On August 25, 2005, the Plaintiff, UDD, and LB transferred to AB only O, O, and O only shares of AA on the same day, and UDR transferred U.S. shares of AA to U.S. (hereinafter referred to as U.S. transaction in 2005).

3) On August 29, 2008, UD, UCC, and LB transferred AB stocks additionally to AB (in 2008, each PD and UCC, each PBO, hereinafter “2008 transaction”); as a result, the Plaintiff et al. did not own the shares of AB but indirectly own the shares of the AB (indirect “indirect” is multiplied by the shares ratio of the Plaintiff et al. against AB held by AB).

4) Before August 29, 2008, the Defendant: (a) indirectly held OB shares of AB through OB (OB only OB shares of AB owned by AB x 51% of the Plaintiff’s shareholding ratio); (b) determined that indirect shareholding has increased by OB (OB shares owned by AB x 51% of the Plaintiff’s shareholding ratio x 51% of the Plaintiff’s shareholding ratio) through transactions in 2008; (c) on January 11, 2012, the Defendant deemed UB shares transferred from AB (hereinafter “instant shares”) as subject to gift tax; and (d) determined and notified each gift tax as indicated in attached Table A (hereinafter collectively referred to as “instant disposition imposing gift tax”).

5) At the time of the imposition of the gift tax in this case, the Defendant calculated the value of the instant shares as an OO per share in accordance with the supplementary assessment methods stipulated under Article 63 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9269 of Dec. 26, 2008; hereinafter the same) and Article 54 of the Enforcement Decree of the same Act at the time of the imposition of the gift tax in this case. The details of the calculation of the specific amount of tax on the basis thereof are as stated in the attached

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 7, Gap evidence Nos. 23 through 28, Eul evidence Nos. 1, 2 and 5 (including each number), and the purport of the whole pleadings

3. The plaintiff's assertion

A. Regarding the instant disposition imposing global income tax

This Court's explanation is the same as the 6th court's 18th to 7th 5th eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth eth.

B. As to the imposition of gift tax of this case

This Court's explanation is the same as the statement in the 7th judgment of the court of first instance in accordance with Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

4. Relevant statutes;

Attached 3 is as shown in the "related Acts and subordinate statutes".

5. Determination on the disposition imposing global income tax of this case

With respect to this part, the court's instructions are the same as the entry of the second to third parties of the judgment of the first instance, except for the addition of the "(the same shall apply in addition to the entries of the evidence No. 6 and No. 7 submitted by the defendant at the appellate court)" of the first instance court's 13th 1th 13th 1th 13th 4th 1th 13th 1th 2th 8th 13th 1th 8th 8th 13th 1th 13th 1th 2th 8th 13th 1th 200 of the Administrative Litigation Act, and they

6. Determination on the imposition of gift tax of this case

This Court's explanation is the same as the statement in the first instance court's 14th 2 to 15th 15th eth eth 15th eth eth eth 9, in addition to adding "(the same shall apply even if the defendant's written evidence Nos. 8-1, 2, 9, 10 was added to the written evidence No. 8-1, 2, 9, 10 which was submitted by the appellate court)" following the part of the 15th eth eth eth 9th eth eth eth eth s.g.

7. Conclusion

Therefore, the plaintiff's claim as to the part on which the defendant appealed shall be quoted on the ground of its reasoning, and the judgment of the court of first instance is just in conclusion, and the defendant's appeal is dismissed as it is without merit. It is so decided as per Disposition.