1. The Defendant’s disposition rejecting to rectify the gift tax made against the Plaintiff on September 27, 2016 is revoked.

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

1. Details of the disposition;

A. On October 27, 2014, B Co., Ltd. (hereinafter “instant company”) resolved to issue new shares by holding a board of directors on October 27, 2014.

1. The types and number of new shares: 32,395 common shares;

2. Par value of one share: 10,000 won per share;

3. The issue value of new stocks: 216,080 won per share;

4. Method of acquiring new stocks: A new stocks shall be allocated in proportion to the number of stocks held by each shareholder, and the new stocks that the shareholder renounces the right may be publicly offered from another general person or may be underwritten by another general person; and

5. Other procedures necessary for issuing new stocks shall be entrusted to the representative director.

B. On October 28, 2014, the instant company offered 32,395 shares with capital increase. The Plaintiff acquired 20,247 shares of the instant company’s shareholders who renounced the subscription (hereinafter “instant shares”), and thereafter, the Plaintiff held 1,137,500 shares of the instant company through capital increase without compensation and par split as follows.

On October 28, 2014, the number of shares issued for capital increase on March 20, 2015; 36,628 May 1, 2015; 1,080,625 in total at par value; 1,137,500

C. The instant company was listed on the KOSDAQ on December 17, 2015, and the Plaintiff filed a claim to rectify the amount of tax to be paid as KRW 350,320,338,00, regardless of the largest shareholder, on the premise that the Plaintiff’s possession of 1,137,500 shares of the instant company constitutes subject to taxation under Article 41-3 of the former Inheritance Tax and Gift Tax Act (Amended by Act No. 13557, Dec. 15, 2015; hereinafter “former Inheritance Tax Act”). On June 30, 2016, the Defendant filed a return on KRW 352,320,338 of the gift tax pursuant thereto to the said Act to the Defendant on June 30, 2016, on August 29, 2016, on the ground that the instant shares, etc. do not constitute the subject of taxation, regardless of the largest shareholder by the third party allotment method, and thus, the Defendant also filed a claim to rectify the amount of tax to be paid.