1. All appeals by the Defendants are dismissed.

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

Purport of claim and appeal

1.

1. The reasons for the court's explanation concerning this case are as follows. Paragraph (3) is the same as the reasons for the judgment of the court of first instance, except for the addition of the judgment on the new argument by the head of Jongno-gu Seoul Metropolitan Government, the head of Jung-gu Seoul Metropolitan Government, and the head of Yeongdeungpo-gu Seoul Metropolitan Government, the head of Yeongdeungpo-gu, and the head of Yeongdeungpo-gu, Seoul Metropolitan Government, as stated in the reasoning for the judgment of the court of first instance. Thus, this is cited in accordance with Article 8(2

2.The 12th page 7 to 9 of the parts to be removed or added are as follows:

The tax authorities of Luxembourg issued resident certificates with respect to the SICV or the SICF, which received more than 98% of the domestic source income of this case among the instant SICV, that “the relevant SICV or the SICF constitutes a resident of Luxembourg, and is not a holding company in accordance with the laws and regulations of 1929 and the Decree of 1938,” and that “the relevant SICV or the SICF is not a holding company in accordance with the laws and regulations of 1929 and the Decree of 1938.” Based on the 13th page of the 4th page of the “The grounds for recognition,” the 4th page of the 4th page of the “

The term "the testamentary donee" in Part 14 of the 14 shall be raised to "the owner".

From Luxembourg's 16th to Luxembourg's 17th to 'the issue' is as follows:

The Luxembourg tax authorities issue resident certificates for most of the instant SICV to the effect that “the relevant SICV or SICF is a Luxembourg resident under the Korea-Luxembourg Tax Treaty” (On the other hand, the Defendants are not able to recognize their resident status in the case of SICV or SICF for which no resident certificate is submitted by the Luxembourg tax authorities. However, it is difficult to deem that the tax authorities’ resident certificate is required for the recognition of resident status under the tax treaty, and on most of the remaining SICV or SICF established and operated under the same law.