this agreement constitutes a fraudulent act.

Since the mother's mother's act of establishing a right to collateral security is a fraudulent act against a delinquent taxpayer's property, he/she must implement the procedure for cancellation registration of establishing a right to collateral security.

Article 30 of the National Tax Collection Act: Revocation and Restoration of Fraudulent Act

2014 Ghana 214386 Revocation of Fraudulent Act

Korea

KimA

June 12, 2014

June 26, 2014

1. The establishment of a collateral security agreement concluded on January 28, 2013 between the defendant and KimB (OO-OOOOOO) is revoked.

2. On January 28, 2013, the Defendant fulfilled the registration procedure for cancellation of the registration of establishment of the right to collateral security, which was made by the receipt OOOO on the above real estate, to KimB.

3. The costs of lawsuit shall be borne by the defendant.

Cheong-gu Office

The same shall apply to the order.

1. Indication of claim;

The reasons for the attached Form shall be as shown in the attached Form.

2. Judgment on deemed confession (Article 208 (3) 2 of the Civil Procedure Act).

Cheongwon of the Gu

1. The relationship between Defendant and Nonparty KimB

“The Defendant is the head of Non-Party KimB (hereinafter referred to as “Non-Party”) in arrears. (No. 1, 2, and family relation certificate)

2. Details of the taxation claim, which is a preserved bond

"A. The non-party is a business operator who has engaged in financial/securities trading business under the trade name "OO-Gu O-dong 516-45CC distribution" from January 05, 2006 to December 31, 2012. (A)"; (b) although the non-party has faithfully filed a tax return in accordance with the relevant statutes and voluntarily paid the relevant national taxes, he/she has under-reported the total income tax for the business performance from 2009 to 2011 and received an investigation from the Non-Party for the payment period of KRW 300,000,000 for the total amount of KRW 40,000,000 and KRW 30,000,0000,000 for the total amount of KRW 13,000,000,0000,000,0000,0000,0000,0000,000).

Resolution on Correction of Global Income Tax

Resolution on Correction of Global Income Tax

A written resolution for correction of global income tax (2012), "in case of default (taxpayer)", and "record 1" details of preserved claims (in case of minor arrears) (as of March 2014)

(unit: Won)

Sub-Items :

E =

Date of establishment of tax liability

Deadline for payment

Notice Tax Amount

Amount in arrears

(including additional charges)

Global Income Tax

209

December 31, 2009

2013.04.30

OOO

OOO

Global Income Tax

2010

December 31, 2010

2013.04.30

OOO

OOO

Global Income Tax

2011

December 31, 201

2013.04.30

OOO

OOO

Global Income Tax

2012

December 31, 2012

8.31.20

OOO

OOO

Total

OOO

OOO

3. Fraudulent act and reduction of liability property;

"A. The Nonparty: (a) established the basic legal relationship of the taxation claim related to the above preservation claim; (b) during the period from the investigation and investigation conducted on January 21, 2013 to February 22, 2013, the Non-party predicted that he/she will be notified of the high global income tax in the near future or under high probability; and (c) reduced his/her property by completing the registration of establishment of the right to collateral security with the Defendant on January 28, 2013, as the real estate listed in the attached list, and the real estate listed in the attached list, which was owned by him/her, and the Non-Party reduced his/her property by completing the registration of establishment of the right to collateral security with the Defendant on January 28, 2013, which led to the result that the Plaintiff was unable to obtain the satisfaction of the taxation claim (the entire certificate of registration No. 3)" (b) the above high probability that the national tax amount is notified.

C.The non-party's act of setting up the real estate stated in the attached list with the defendant is not paid national taxes notified to him, but has not been paid up to now. (See Supreme Court Decision 2002Da42957, Nov. 8, 2002). (c) The establishment of the right to collateral security during the investigation period at the Seosan Tax Office (Supreme Court Decision 2002Da42957, Nov. 8, 2002), the mortgagee of the real estate listed in the attached list is the mother of the non-party, and the notified national tax has not been paid at all until now.

4. Intention and bad faith of the defendant;

The non-party, upon receiving an investigation from the investigation of the Busan District Tax Office, was anticipated to be notified of the global income tax amount in the near future, or at the time of the establishment of the right to collateral security with the defendant, he was aware of the plaintiff as the tax payer at the time of the establishment of the right to collateral security with the defendant. The defendant, as the mother of the non-party, should be deemed to have known of the fact that this act was a fraudulent act and the intention of the non-party's deliberation.

5. Whether the property is current;

"The date when the director of Busan Regional Tax Office and the director of Seosan District Tax Office have investigated the property of the non-party for the purpose of the disposition on default, as shown in the summary inquiry by each taxpayer (Evidence A No. 4).", "The date when he becomes aware of fraudulent act on June 1, 200."

In order to execute a disposition on default against the Nonparty by a public official belonging to the Busan District Tax Office of Korea, Busan District Tax Office, issued on December 2013 a full certificate of the registered matters concerning the instant real estate and became aware of the fact that the establishment of a collateral security has been completed in the name of the Defendant and the Nonparty’s fraudulent act.

7. Conclusion

In light of the above facts, the Nonparty’s act of setting up a collateral to the Defendant with OOO on 28, 2013 regarding the real estate listed in the attached list constitutes a fraudulent act, which is an act of knowing that it would prejudice the Plaintiff in order to evade tax liability. Thus, the Plaintiff is bound to file a claim as stated in the purport of the claim in accordance with Article 406 of the Civil Act and Article 30 of the National Tax Collection Act.