1.(a)

The director of the tax office of South Korea has limited to the plaintiff corporation A, C Bank, E Bank, F Securities Company, and G.

A. Therefore, the part of penalty tax for nonperformance of withholding duty in the instant disposition is unlawful, as there are justifiable grounds for the Plaintiffs’ failure to fulfill withholding duty.

(b) Entry in the attached Form of relevant statutes;

(c) Article 28 of the facts of recognition is not applicable to holding companies within the meaning of the Special Act of Luxembourg, that is, the Special Act of Luxembourg, that is, the Act of 31 July 1, 1929 and the Act of 17 December 1939* or any similar Act enacted by Luxembourg after the signature of this Convention.

In addition, this Convention shall not apply to the income acquired by a Korean resident from such holding company and to the shares or other rights of such company owned by that person.

28 Exclor 28 Exclor 28 exclor 28 Exclor of the Regulation of the Punishment of the Local Public Officials, which provides for the exclusion of application to the hringcom to the hring ing to the hall mal, for the exclusion of application to the 31stmor 31 July 1929 and 17th 1938 Dec c member 1938 * Luxemblor Dom 1938 * 1938 Domurururur, which provides for the exclusion of application to the 31stmor hall hall mal mar lave from the Maritime Affairs and Fisheries Association to the hring hring hall mor mor 2.

* The Korean translation of the Korea-Luxembourg Tax Treaty is written in 1939, but the English version is written in 1938, as it is written in 1938.

(2) The legislative intent and main contents of the Act on the Taxation System of Holding Companies of 1929, enacted on July 31, 1929, including the amendments in 1971, 1977, 1978, and 199, shall be as follows: (a) at least a level similar to that of the Republic of Switzerland or of the Republic of Luxembourg in order to provide benefit in favor of the establishment of holding companies in Luxembourg; (b) the legislative intent and main contents of the Act including the amendments in 1971, 197, 198

b)the double taxation is disadvantageous to the payment of income between countries;