1. Revocation of a judgment of the first instance;

2. Acquisition tax assessed against the Plaintiff on April 2, 2015 is KRW 55,934,420, and is assessed against the Plaintiff.

1. The grounds for the judgment of this court partially citing the judgment of the court of first instance are as follows: “The developments leading to the disposition of this case” and “the lawfulness of the disposition of this case

A. The plaintiff's assertion;

B. Relevant statutes are identical to the pertinent part of the reasoning of the judgment of the first instance court (from the second to fourth and 9 pages, up to the 11 pages). As such, Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act are cited. 2. The part which differs from the first instance judgment of the second instance, 1) Article 105(6) of the former Local Tax Act (wholly amended by Act No. 10221, Mar. 31, 2010) is deemed to have been acquired when a corporation becomes an oligopolistic stockholder by acquiring stocks or shares of the corporation, that oligopolistic stockholder shall be deemed to have acquired the relevant corporation’s real estate.

Article 120(6)8 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010) provides that “Where a holding company (including a financial holding company) under the Monopoly Regulation and Fair Trade Act (hereinafter “Fair Trade Act”) or a holding company falls under an oligopolistic stockholder under subparagraph 2 of Article 22 of the Local Tax Act by acquiring stocks of a subsidiary under the same Act or the Financial Holding Companies Act, Article 105(6) of the former Local Tax Act concerning the imposition of deemed acquisition tax shall not apply to such oligopolistic stockholder.

"" is defined as ".

The legislative intent of Article 120(6)(8) of the former Restriction of Special Taxation Act, except for the subject of deemed acquisition tax, is to support corporate restructuring for the rationalization of ownership and management by granting tax benefits to the establishment of holding companies or the conversion of holding companies.

Therefore, even if a holding company is already established or converted under the Fair Trade Act, if there is a corporate restructuring that becomes a holding company in the domestic company by newly incorporating a domestic company into a subsidiary, it shall be a new holding company.