The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. Articles 119(1)10 and 120(1)9 of the former Restriction of Special Taxation Act (amended by Act No. 9921, Jan. 1, 2010; hereinafter “former Special Taxation Act”) provide for exemption from registration tax for the registration of property acquired due to “division meeting the requirements under each subparagraph of Article 46(1) of the Corporate Tax Act” and acquisition tax for the acquisition thereof.

Meanwhile, Article 46(1)3 of the former Corporate Tax Act (amended by Act No. 9898, Dec. 31, 2009; hereinafter the same) provides that "a corporation established by division shall continue to operate a business succeeded to from a divided corporation by the end date of the business year in which the registration date of the division falls." Article 46(1)3 of the same Act provides that "a corporation established by division shall continue to operate a business succeeded to from the divided corporation by the end date of the business year which includes the registration date of the division

Article 82(4) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 22184, Jun. 8, 2010; hereinafter the same) provides that Article 80(3) and (6) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 22184, Jun. 8, 2010; hereinafter the same) shall apply mutatis mutandis to the determination of the continuation or discontinuance of the business of a corporation established through division, and Article 44(1)3 of the former Enforcement Decree of the Corporate Tax Act provides for the same purport as Article 46(1)3 of the Corporate Tax Act with respect to the merger, the former Enforcement Decree of the Corporate Tax Act provides that “if the surviving corporation disposes of more than 1/2 of the value

In light of the language and text, structure, etc. of these regulations, a corporation established through division succeeds to business from a divided corporation before the end of the business year in which the registration date of the division belongs