The judgment of the court below is reversed, and the case is remanded to Daejeon High Court.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Article 10(1) of the Convention between the Government of the Republic of Korea and the Government of the United Kingdom for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Transfer Income (hereinafter “Korea-U.K. Tax Treaty”) provides that “The dividends paid by a corporation which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other Contracting State,” and Article 10(2) provides that “However, with respect to such dividends, the said dividends may be taxed in accordance with the laws of the Contracting State in which the corporation paying the dividends is a resident. However, if the payee is a beneficial owner of the dividends

In the item, "at least 25 percent of the voting rights of a corporation for which profit-making owners pay dividends is a corporation (excluding partnership) directly or indirectly controlled by a corporation (excluding partnership), the total amount of dividends shall be five percent."

In addition, Article 14(1) of the Framework Act on National Taxes provides that "if the ownership of income, profit, property, act or transaction subject to taxation is merely nominal, and there is a separate person to whom such income, profit, act or transaction belongs, the person to whom such income, etc. belongs shall be liable

The substance over form principle under Article 14(1) of the Framework Act on National Taxes, in cases where there is another person to whom such income, profit, property, transaction, etc. belongs, unlike the nominal person, is not the nominal person, but the person to whom such income, profit, property, or transaction, etc., belongs, is the person to whom such income, profit, property, or transaction, etc., belongs. Therefore, the nominal person to whom the property,