1. All appeals by the Defendants are dismissed.

2. The costs of appeal are assessed against the Defendants.

Purport of claim and appeal

1.

1. The reasoning of the judgment of this court citing the judgment of the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except for the addition of the judgment as to the allegations in the court of first instance as set forth in paragraph (3) below, and thus, it is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of

2. Additional determination

A. The Defendants’ assertion 1) The Local Tax Act amended by Act No. 13427, Jul. 24, 2015 (hereinafter “Revised Local Tax Act”) (hereinafter “Revised Local Tax Act”).

(2) Unlike personal local income tax, Defendant Bupyeong-gu asserts to the effect that it cannot be imposed by applying the amended Local Tax Act as it does not have any special transitional provision regarding corporate local income tax, and thus, even if Article 49(1) of the former Framework Act on National Taxes is applied or applied mutatis mutandis with respect to each disposition of this case, the scope of such additional tax shall be divided in proportion to each local government within the limit of KRW 100 million, as prescribed by the express text. As such, the amount of KRW 1,514,211, among the disposition imposing the additional corporate local income tax of Defendant Bupyeong-gu head, is calculated by applying the proportional distribution ratio of KRW 100,00,000,000, which is one of the limit of corporate income tax under Article 49

The part argues that it is legitimate.

B. As to the first argument on the first argument, the Defendants: (a) applied Article 103-30(5) of the Local Tax Act to the Plaintiff at the time when the liability to pay corporate local income tax was established; and (b) applied Article 86(2) of the Local Tax Act and Article 147 of the former Framework Act on Local Taxes to the effect that Article 49(1)2 of the former Framework Act on National Taxes may apply or apply mutatis mutandis to each of the instant dispositions; (c) thus, it cannot be deemed that the amended Local Tax Act, which is not a key issue, is retroactively applied to each of the instant dispositions.

Therefore, it is based on the premise that the revised Local Tax Act was retroactively applied with respect to each disposition of this case.