1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. The Plaintiff filed a claim for revocation of the imposition of gift tax exceeding KRW 6,214,098 among the imposition of gift tax of KRW 17,207,60, and KRW 17,204,863 among the imposition of global income tax of KRW 17,206, and KRW 6,214,098 among the imposition of gift tax of KRW 1,208, KRW 2009, KRW 209, and KRW 209, KRW 209, KRW 200, KRW 130 as stated in attached Table 1. The judgment of the first instance rejected the Plaintiff’s claim on the imposition of gift tax of KRW 1,208, KRW 209, and KRW 201, KRW 140 as stated in attached Table 1.

With respect to this, only the defendant appealed the part against him, and the plaintiff did not appeal.

Therefore, the scope of this Court’s adjudication is limited to the imposition of each gift tax as stated in attached Table 1(a) and each comprehensive disposition as stated in subparagraph (b) (each global income tax disposition as of 2008, 2009, and 2010).

2. Details of the disposition;

A. The status of the Plaintiff and its related company B (hereinafter “B”)

(2) On December 30, 1986, the Plaintiff was established as a domestic corporation specialized in the production and sale of opporter system, the core location of plastic withdrawn type, and 58% of the issued stocks as of the end of 2010, and the remainder of 42% of the issued stocks are owned by C, children D, and E, respectively. (2) The Plaintiff and B established an overseas corporation performing the functions of a manufacturing company, selling company, or holding company in China, Hong Kong, Europe, U.S., etc. for the overseas production and sale of the opporter system, etc. (hereinafter referred to as “F”), and the corporation related to the instant case is as follows:

b) G (hereinafter referred to as "G") is a corporation established in Hong Kong in October 2003, which functions as a holding company of Hong Kong and B affiliated companies located in China. The Plaintiff and the Plaintiff, a legal entity incorporated in the United Kingdom of Ireland on July 7, 2005, for the purpose of owning F.