1. The Defendant imposed gift tax of KRW 510,760,810 on Plaintiff A on January 12, 2016 (including penalty tax) and Plaintiff B.

Details of the disposition

C Co., Ltd. (hereinafter “C”) was mutually changed to “Co., Ltd. D” on March 29, 2016, and the purpose of which is to manufacture, sell, maintain and repair semiconductor-related equipment and parts, and service business.

On March 2010, the total number of C’s issued shares was 9,400,000 shares, and among them, the Plaintiff held 3,531,014 shares (37.56%), E, the head of the Plaintiff, 80,80 shares (0.86%) and 80,00 shares (0.85%) respectively.

F Co., Ltd. (hereinafter referred to as “F”) is a company with the purpose of manufacturing, selling, maintaining, and providing services, etc. equipment and parts relating to semiconductors.

The F's total number of outstanding shares is 60,000 shares, and the plaintiff A holds 12,000 shares (20%) and the plaintiff E and the plaintiff B own 24,000 shares (40%) respectively.

C Co., Ltd. (hereinafter “G”) issued bonds with warrants (hereinafter “instant bonds”) with the total face value of KRW 6,00,000,000, surface interest rate of KRW 00,400, maturity guarantee return rate of KRW 7%, date of issuance April 7, 2010, maturity of April 7, 2013, and maturity of April 7, 2013 (hereinafter “instant bonds”) with the subscription of G as an underwriter on April 6, 2010. From the date one year has elapsed ( April 7, 201) to 30 days ( March 8, 2013) with the due date of maturity of KRW 2,521,07 with the subscription of 2,380,00 per share, and G and F entered into an underwriting contract with the subscription of 60,000,000,000,000 won per share (hereinafter “instant bonds”) and transferred 60,015,000,00.

G acquired the instant bonds on April 7, 2010, and transferred the instant preemptive right to F to the instant bonds, and F exercised the instant preemptive right on March 7, 2013 while holding the instant preemptive right.

The Defendant: (a) acquired preemptive rights and exercised such rights, thereby gaining profits of KRW 6,329,949,400; (b) thereby deeming the Plaintiffs, the shareholders of F, to have received benefits corresponding thereto from C; and (c) on January 12, 2016, the Plaintiff 510,760.