1. All the disposition imposing gift tax (including additional tax) on the Plaintiff as set out in the separate sheet of imposition No. 1 attached hereto.

Details of the disposition

From May 14, 2007 to June 30, 2010, the Plaintiff borrowed a total of KRW 18,754,690,000 (hereinafter “the instant money”) from B, and the details thereof are as shown in attached Table 2.

On November 21, 2016, the Plaintiff and B entered into an agreement on repayment of loans (hereinafter “instant repayment agreement”) retroactively with respect to the terms and conditions of interest payment on loans, and set the interest rate as zero-year interest rate until 2012, and one-year interest rate for the portion after 2013 (hereinafter “instant agreed interest rate”).

In accordance with the instant repayment agreement, the Plaintiff repaid KRW 794,625,120 (interest rate 2.6% in 2013, and 2.2% in 2014) as interest from November 28, 2016 to B in 2014, and withheld and paid interest income tax (including local income tax) 218,521,908.

In addition, on September 27, 2017, the Plaintiff repaid 622,120,290 won (1.8% of interest rate in 2015, 1.3% of interest rate in 2016) to B from September 27, 2015, and paid interest income tax (including local income tax) 171,083,060 won through withholding.

The Seoul Regional Tax Office conducted a gift tax investigation from March 31, 2017 to September 22, 2017 on the Plaintiff’s 2013 to 2016, and the Plaintiff revised B several times in this case of the Inheritance Tax and Gift Tax Act from March 2013 to 2016, but the Enforcement Decree of the Inheritance Tax and Gift Tax Act, which applies in the taxable period of gift tax from 2013 to 2016, has been amended several times, but the specific content of the investigation is large. Therefore,

(hereinafter referred to as “the case of receiving a loan at an interest rate lower than the pertinent interest rate”) under Article 41-4 of the Inheritance and Gift Tax Act, and notified the Defendant of relevant data.

Accordingly, the defendant, on November 9, 2017, is in accordance with Article 31-4 (1) of the Enforcement Decree of the Inheritance and Gift Tax Act and the Ministry of Strategy and Finance notice concerning the amount of this case.