Property tax and -306 (No. 27, 2011)

Certificates of merit

A corporation, at least 50/100 of the total number of outstanding shares of which are invested by the largest shareholder of A corporation and his/her relatives, shall be the largest shareholder.

A who is the largest shareholder of a A and persons who are related by blood under Article 19 (2) 1 of the Enforcement Decree of the Inheritance Tax and Gift Tax Act shall have invested not less than 50/100 of the total number of shares issued and outstanding, and P shall fall under the largest shareholder of A corporation under Article 19 (2) 7 of the Enforcement Decree of the Inheritance Tax

Article 63 of the Inheritance Tax and Gift Tax Act

【Reference Materials】

1. Facts and the contents of the questioning;

O Factual relations

-the applicants have been donated 50,000 non-listed shares 50,000 shares (5% equity ratio) set aside on June 1, 2010, respectively;

- The unlisted stocks were evaluated and reported and paid in accordance with the provisions of the Inheritance and Gift Tax Act;

- A owns listed stocks (A, B, C, and D) as financial investment assets.

- In evaluating the net asset value of the unlisted corporation(A), the appraisal value is different depending on the application of the provision on appraisal of evidence to the largest shareholder under Article 63(3) of the Inheritance and Gift Act;

- Shares held by A of an unlisted corporation