1. Of the instant lawsuit, the imposition of the acquisition tax-free penalty amounting to KRW 2,391,358,650 on September 5, 2016 by the Defendant Tong Young-market.

1. Details of the disposition;

A. 1) The Plaintiff is a special financial institution established under the Export-Import Bank of Korea Act to provide financial support necessary for external economic cooperation. The Plaintiff is a Seongdong Shipbuilding Marine Co., Ltd. (hereinafter referred to as “Madong Shipbuilding”).

(2) The Plaintiff and the financial institutions, the creditors of the Sung-dong Shipbuilding, were established by a creditor council of creditor financial institutions on March 31, 2010 and entered into an implementation agreement for the business normalization of the Sung-dong Shipbuilding. 2) The Plaintiff, as part of the business normalization of the Sung-dong Shipbuilding, converted loans of KRW 76,67 billion into equity and owned shares of KRW 76,794,100 (80.25%) among the shares issued by Sung-dong Shipbuilding. Accordingly, the Plaintiff became an oligopolistic shareholder as provided for in Article 7(5) of the former Local Tax Act (Amended by Act No. 13636, Dec. 29, 2015).

3) The Plaintiff is not subject to Article 7(5) of the former Restriction of Special Taxation Act (amended by Act No. 12853, Dec. 23, 2014; hereinafter “Special Taxation Restriction Act”) where a financial institution becomes an oligopolistic stockholder by converting its loans into investment.

(B) Since the Plaintiff did not have an obligation to pay deemed acquisition tax pursuant to Article 120(6)2 of the Local Tax Act, the Plaintiff did not file a return on acquisition tax pursuant to Article 7(5) of the Local Tax Act. (b) After the lapse of the period, the Plaintiff did not have an obligation to pay acquisition tax itself, but was paid the special rural development tax by filing a return after the lapse of the period, knowing that the special rural development tax is not exempted. Although the Plaintiff did not pay acquisition tax, the Plaintiff received a notice from the Defendants that the return of acquisition tax itself is not exempted even if the Plaintiff did not pay acquisition tax, and paid non-