1. The plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. The Plaintiffs held 2,400,000 shares out of the total number of shares issued 8,267,298 (29.03% of the total number of shares issued) and 1,254,50 shares out of the total number of shares issued 8,267,298 (15.17% of the total number of shares issued) and 1,250 shares out of 8,267,298 (15.17% of the total number of shares issued).

(2) On October 19, 2016, the Plaintiffs (hereinafter “instant shares”) transferred the instant shares to D Limited Company KRW 45,970,721,029 (Plaintiff A) and KRW 24,029,278,971 (Plaintiff B), and reported and paid the capital gains tax to the Defendant by applying 20% of the capital gains tax rate as follows:

(Unit) On December 4, 2017, 2017, the Plaintiff filed a claim for correction with the following grounds: (a) “The former Income Tax Act (amended by Act No. 14389, Dec. 20, 2016; hereinafter the same) (amended by Act No. 14389, Dec. 20, 2016; hereinafter the same) which was in force at the time of the transfer of the instant shares is limited to a major shareholder of a stock-listed corporation; (b) the transfer of the instant shares, which are stocks of a stock-listed corporation, by the Plaintiffs, are not a major shareholder of a stock-listed corporation, shall be subject to the application of 10% capital gains tax rate in cases of transfer by a person who is not a major shareholder under Article 104(1)11 (b) of the former Income Tax Act; and (c) the portion exceeding the legitimate capital gains tax (the Plaintiff A shall be subject to 4,549,836,742 won, Plaintiff B shall be refunded.

The defendant means both a major shareholder of a stock-listed corporation and a non-listed corporation under the former Income Tax Act, and the plaintiffs constitute a major shareholder of a stock-listed corporation, and thus the plaintiffs' transfer of the plaintiffs' shares constitutes a major shareholder of a stock-listed corporation, and thus, 20% of the transfer income tax rate under Article 104 (1) 11 (c) of the former Income Tax Act shall apply to the transfer of shares