1. On January 13, 2015, the Defendant imposed acquisition tax of KRW 509,315,490 and special rural development tax of KRW 43,058,970 on the Plaintiff.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “B”) was established on October 23, 2003. At the time of incorporation, B’s shareholder registry entered C’s 10,000 shares out of 20,000 shares, and Plaintiff and D held 5,00 shares, respectively.

B. On December 20, 200, 5,000 shares of D were transferred to the Plaintiff on December 20, 2007, and on December 21, 2007, 2007, each of 20,000 shares out of 40,000 shares issued additionally as the capital amount of KRW 200 million was acquired under the name of the Plaintiff and C, and thereafter, the register of shareholders of B after the capital increase was recorded as holding 30,00 shares, respectively.

C. B’s statement of the change in stocks, etc. in 2013 indicated that the Plaintiff opened 30,000 shares of C in the name of the Plaintiff in the year 2013 (hereinafter “instant shares”) to hold 100% of the shares issued by B. The Defendant imposed acquisition tax on the Plaintiff on January 13, 2015, by deeming that the Plaintiff acquired the instant shares and thereby became an oligopolistic shareholder pursuant to the main sentence of Article 7(5) of the former Local Tax Act (amended by Act No. 12153, Jan. 1, 2014; hereinafter “former Local Tax Act”).

(hereinafter “Disposition in this case”). [Grounds for recognition] The fact that there is no dispute, entry of Gap’s evidence Nos. 1 through 6 (including branch numbers; hereinafter the same shall apply), the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The beneficial shareholder of the Plaintiff’s assertion of the instant shares is the Plaintiff, and C is merely a nominal shareholder of the form that received the instant shares from the Plaintiff.

Therefore, the Plaintiff’s entry of the instant shares in the name of the Plaintiff in the name of the Plaintiff does not constitute a case where the Plaintiff acquired shares because it was merely the termination of the existing title trust and the recovery of the shareholder’s name. However, on the premise that the Plaintiff acquired the instant shares, it is against the Plaintiff.