1. All appeals by the defendant against the plaintiffs are dismissed.

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

purport, purport, and.

The reasoning of this court's ruling is as follows: Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act are as follows, except for the addition of the following to Chapter 9 of the judgment of the first instance.

【The Defendant asserts that, as the requirements for applying the limited tax rate on dividend income, Article 10(2)(a) of the Korea-Japan Tax Treaty provides that “the “the “the “the “combim” shall be deemed to have been issued at the time of issuance, the issue of voting stocks shall be determined at the time of issuance. Therefore, its own stocks shall be deemed to be voting stocks. However, the stocks of a corporation shall be naturally issued by a corporation, and the corresponding country shall be deemed to be issued by a corporation, and the corresponding country shall be “the voting stocks issued by a corporation,” “the “the “the “corporation’s voting stocks” shall be deemed to be “the “the “corporation’s voting stocks”, and it is difficult to interpret the language to determine whether voting stocks are issued at the time of issue beyond the meaning, and it is difficult to interpret the meaning of the “isued” as at the time of issue. Accordingly, the Defendant’s above argument is not acceptable. The Defendant