All appeals are dismissed.

The costs of appeal are assessed against the Defendants.

The grounds of appeal are examined.

1. As to the ground of appeal No. 2, Articles 37(1) and 41-4(1)1 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 11130, Dec. 31, 201; hereinafter “the Act”) provide for the donation of profits from the free use and lending of real estate and money, respectively, as to the donation of profits from the free use and lending of the remaining property other than real estate and money, Article 42(1)1 of the Act provides for separate provisions concerning donation of profits from the free use of the property other than real estate and provision of services under Article 42(1)2 of the same Act, and provides for separate provisions concerning donation of profits from the free use of property separate from the donation of profits from the free provision of services. In light of the above, the profits equivalent to the appropriate interest rate from the free lending of money under Article 41-4(1)1 of the Act does not constitute “profit from the provision of services” under Article 42(1)2 of the Act.

(1) The lower court’s determination to the same purport is justifiable to the effect that the profit equivalent to the interest amount calculated by multiplying the money that the Plaintiffs received free of charge from C, which was not specially related, by the annual interest rate of 8.5% or 9% per annum under Article 41-4(1)1 of the Act, does not constitute “the profit that the Plaintiffs received by the provision of services without compensation” under Article 42(1)2 of the Act. In so doing, the lower court did not err by misapprehending the legal doctrine on the interpretation and application of Article 42(1)2 of the Act, thereby failing to exhaust all necessary deliberations.

2. Regarding ground of appeal No. 1

A. Article 2(3) of the Act introduces a comprehensive gift concept unique to the tax law and Articles 32 through 32 of the former Regulations on Donation Donation for the purpose of prior countermeasures against irregular inheritance and inheritance.