1. The plaintiffs' appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. Details of the disposition;

A. Title trust 1) Stock Co., Ltd. C (hereinafter “C”).

A) A corporation is engaged in real estate development, lease, and sale. D around January 2005, acquired C’s 4,00 shares under Plaintiff A’s name, and 1,33 shares under Plaintiff B’s name (hereinafter “each of the above shares is referred to as “former shares before capital increase,” and “first title trust”) C’s face value per share under the shareholder allocation method on March 5, 2010, with KRW 10,667 shares as KRW 9,67 shares. D paid the capital increase under Plaintiff’s name, and acquired KRW 7,251 shares under Plaintiff B’s name, and KRW 2,416 shares under Plaintiff B’s name (hereinafter collectively referred to as “instant shares”). B. The title trust of the instant shares is referred to as “second title trust”).

The head of Seoul Regional Tax Office of Disposition conducted an investigation with respect to C, and confirmed that D was in title trust with the Plaintiffs, and notified the Defendant thereof. The Defendant respectively imposed gift tax of KRW 8,337,229,380 (including additional tax of KRW 2,461,182,314) on July 2, 2012 by applying the provision on deemed donation of title trust under Article 45-2(1) of the Inheritance Tax and Gift Tax Act (hereinafter “Inheritance Tax Act”) on July 2, 2012, the Plaintiff imposed gift tax of KRW 2,342,72,72,640 (including additional tax of KRW 691,580,773) on the Plaintiff.

(C) Each disposition imposing gift tax on the Plaintiffs (hereinafter “each disposition of this case”).

The Plaintiffs were dissatisfied with each of the dispositions of this case and filed an appeal with the Tax Tribunal on September 21, 2012, but all appeals filed on August 14, 2013 were dismissed.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, 4, 5, 6, Eul evidence No. 1 (including branch numbers), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiffs asserted that they participate in G remodeling projects in the case of the primary title trust.