1. All appeals by the Defendants are dismissed.

2. The costs of appeal are assessed against the Defendants.

Purport of claim and appeal

1.

1. The reasons cited in this case are the same as the reasons stated in the judgment of the court of first instance, except for the reasons cited in the following 2.2. Thus, they are cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2.As follows, Chapters 20, 13, 21, and 4, of the first instance judgment shall be followed.

B) Meanwhile, the Defendants cannot see B as the conduit and thus, even if they are international transactions between the Plaintiff and B, if their transaction price falls short of or exceeds the arm’s length price, the Adjustment of International Taxes Act (amended by Act No. 9914, Jan. 1, 2010; hereinafter “State Assistance Act”) is applicable at the arm’s length price.

(2) Pursuant to Article 4(1), a domestic corporation’s tax base and tax amount may be adjusted pursuant to Article 4(1). ② The tax authorities of this case between the Plaintiff and J provide that the tax base and tax amount of the resident (including a domestic corporation and a domestic place of business) may be determined or revised on the basis of the arm’s length price if the arm’s length price falls short of the arm’s length price (3.5.79 U.S. dollars per share) of the stock transfer price (5.79 U.S. dollars per share) and the arm’s length price shall be adjusted at the arm’s length price. The difference amount shall be the same as the denied amount of wrongful calculation under the Corporate Tax Act, even if applying the legal principle of the arm’s length price under the State Assistance Act in that the arm’s length price is the same as the amount of wrongful calculation under the Corporate Tax Act, (i) Article 4(1) of the State Assistance Act provides that a foreign related party, which is a foreign related party, may be determined or corrected on the basis of the arm’s length price: