1. A disposition rejecting information disclosure made by the Defendant to the Plaintiffs on April 26, 2016 is revoked.

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

1. Details of the disposition;

A. The Plaintiffs were shareholders of M&T Co., Ltd. (hereinafter “MT”), and transferred M&T shares owned by the Plaintiffs to D on December 5, 2013 at KRW 90,000 per share.

B. On June 10, 2015, the Defendant notified the Plaintiffs of the fact that “The price for the transfer of shares listed in the above paragraph (a) was confirmed to be subject to review of the avoidance of wrongful calculation of capital gains tax as the market price is significantly lower than the market price,” and that the transfer income tax was paid by filing a revised return or the submission of explanatory materials (hereinafter “instant explanatory guidance”).

C. On April 15, 2016, the Plaintiffs filed a claim with the Commissioner of the National Tax Service for the disclosure of “Information on MT’s assessment amount per share and its calculation basis” (hereinafter “instant information”). D.

On April 26, 2016, the Defendant sent reply to the Plaintiffs on the ground that “The instant information is not directly related to the market price of unlisted stocks, and thus constitutes confidential information provided for in Article 9(1)1 of the Official Information Disclosure Act (hereinafter “Information Disclosure Act”) by the Plaintiff’s failure to disclose the instant information.”

(hereinafter “Disposition in this case”). [Grounds for recognition] The fact that there is no dispute, entry of Gap’s evidence Nos. 1 through 3, the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The Defendant asserted that the Plaintiffs sent the instant explanatory guide to the Plaintiffs, which is a type of prior taxation disposition. As such, the Plaintiffs are “taxpayers” rather than “other persons” prohibited from providing the tax information under Article 81-13(1) of the Framework Act on National Taxes, and disclosing the tax information to the Plaintiffs who are taxpayers does not fall under any use other than the intended purpose, and there is no basis to deem that the information may be disclosed only when there is a tax disposition.