1. All appeals filed by the Defendant are dismissed.

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

Purport of claim and appeal

1..

The reasoning of the judgment of the court of first instance is that “107,937,797,91 100,000,000 107,000 107,000 107,000 110,0000 110,0000 110,0000 10,0000 110,0000 110,0000 110,0000,0000 110,0000,0000

The defendant asserts that the 5% limited tax rate under Article 10 of the Korean Tax Treaty cannot be applied to C even in this court.

However, the purpose of double taxation avoidance agreement is to prevent double taxation in the country of residence and the source country, and Article 10 of the Korea- Germany Tax Treaty is to apply the above provision to C inasmuch as the company possessing more than 25% of the investment shares receives dividends from the investment company, it is amended to promote direct investment between the two countries by lowering the limited tax rate on dividend income by 5%. In this case, C owns the plaintiff 100%, C paid corporate tax, operating tax, etc. to the German tax authority, and C paid the above provision after the investment in the F building was achieved.

The Defendant’s assertion is difficult to accept.

The judgment of the first instance is justifiable.

All appeals filed by the defendant are dismissed.