JJJ Co. does not assume the obligation to return unjust enrichment against the amount equivalent to the income tax withheld and paid to the Plaintiffs by the JJ Co.

In light of the fact that there is no provision that subsidies such as income tax shall be reduced from the apartment sale price under the apartment sale contract concluded by the plaintiffs, and that there is a provision that taxes and public charges shall be borne by the buyer out of the subsidies for collection and registration tax, it is difficult to regard Defendant JJJJ or KKK's subsidies for collection and registration tax to be deducted from the sales price, not from other income under the Income Tax Act.

Other incomes in Article 21 (1) 17 of the Income Tax Act

2014 Ghana 42055 Undue gains

1. AA, 2. BB, 3. CCC, 4.D, 5. EE;

6. Limited Liability Company FF, 7. GG, 8. HH, 9. III

1. JJJJJ Co., Ltd., 2. Korea

May 26, 2016

June 9, 2016

1. The plaintiff CCC and DD's lawsuit against the defendant's Republic of Korea shall be dismissed.

2. All of the claims against Defendant JJJJ Co., Ltd. by Plaintiffs AA, BB, EE, Limited Liability Company FF, GG, HH and III are dismissed.

3. The costs of lawsuit are assessed against the plaintiffs.

Cheong-gu Office

Defendant JJJJ Co., Ltd shall pay to the plaintiffs listed in the separate sheet Nos. 1 5% interest per annum from the day following the delivery of the complaint of this case to the day of this decision, and 20% interest per annum from the next day to the day of full payment.

Defendant Republic of Korea shall pay to the Plaintiffs listed in the separate sheet No. 2, 5% per annum from the day following the delivery of the complaint of this case to the day of the pronouncement of this decision, and 20% per annum from the next day to the day of full payment.

Whether Defendant JJJJJ Co., Ltd. (hereinafter referred to as “Defendant JJJ”) or KKK Limited Co., Ltd. (hereinafter referred to as “KK”) bears the responsibility to return unjust enrichment equivalent to the income tax withheld and paid to the Plaintiffs.

In light of the fact that there is no provision that subsidies, such as income tax, should be reduced from the apartment sale price under the apartment sale contract concluded by the plaintiffs, and rather there is a provision that the buyer bears the burden of tax and public charges from the subsidy for the acquisition tax and registration tax, it is difficult to view that Defendant JJJJ or KKK’s subsidy for the acquisition tax and registration tax should be deducted from the sale price, not from other income under the Income Tax Act.

1

Indication of Claim Amount by plaintiff

No.

Plaintiff Name

Amount claimed (won)

1

AA

1,128,204

2

BB

2,078,802

3

EE

2,057,682

4

Limited Corporation FFF

1,818,128

5

GG

1,029,706

6

H H H

1,863,679

7

III

2,820,382

2

Indication of Claim Amount by plaintiff

No.

Plaintiff Name

Amount claimed (won)

1

CCC

1,509,168

2

DD

1,512,000