beta
Title
Where the original registration of ownership is made due to the cancellation of agreement after the commencement of the tax investigation, whether it is the object of wrongful calculation.
Summary
In a case where a tax liability becomes effective by transferring real estate at a low price to a person with a special relationship and completing a settlement of proceeds and a registration of transfer of ownership, the rescission of the agreement on transfer shall be deemed a new agreement that would restore the registration of transfer as originally intended, and the effect of the tax law relationship formed by the initial low price transfer shall not be retroactively extinguished.
Related statutes
Article 52 (Dispudiation of Wrongful Calculation)
Text
1. All appeals filed by the plaintiffs are dismissed.
2. The costs of appeal are assessed against the Plaintiffs.
Purport of claim and appeal
The decision of the court of first instance shall be revoked. The decision of the court of first instance shall be revoked by the head of the military tax office on April 13, 2006. The imposition of KRW 1,037,254,30 of the corporate tax for the year 2004 against the plaintiff corporation ○○○○ Co., Ltd.; KRW 562,721,670 of the corporate tax for the year 2004 against the defendant corporation; and the imposition of KRW 1,273,475,316 of the corporate tax for the year 204 against the defendant corporation ○○○○○○ Co., Ltd. shall be revoked on April 17, 2006.
Reasons
The reasoning for the court's explanation on this case is that "○○○ Co., Ltd.", "526,721,670 won", "52,70 won", "62,70 won", "52,721,670 won," and "transfer contract" of the 7th and 7th 4th 7th 7th 7th 7th 7th 7th 7th 7th 7th 7th 7th 7th 8th 7th 8th 8th 8th 2th 15th 15th 2th 2th 15th 2th 2th 15th 2th 2th 2nd 2nd
Therefore, the judgment of the first instance court is just and without merit, and all appeals by the plaintiffs are dismissed. It is so decided as per Disposition.
[Seoul Administrative Court 2007Guhap31270, 2008.06]
Text
1. All of the plaintiffs' claims are dismissed.
2. All the costs of lawsuit are assessed against the Plaintiffs.
Cheong-gu Office
Defendant ○○ Tax Director’s imposition of KRW 1,037,254,30 for corporate tax of 2004 against Plaintiff ○○○○○○○ Co., Ltd. on April 13, 2006; KRW 562,721,670 for corporate tax of 2004; KRW 562,721,670 for Defendant ○○○○ Co., Ltd. on April 13, 2006; and KRW 1,273,475,316 for corporate tax of 204 for Plaintiff ○○○○○ Co., Ltd. on April 13, 2006.
Reasons
1. Facts of recognition;
A. The Plaintiff ○○○○○○○○○○○○○ (hereinafter referred to as the “Plaintiff’s future”), Plaintiff ○○○○ Investment Information (hereinafter referred to as the “Plaintiff ○○○○”), Plaintiff ○○ Integrated Stock Company (hereinafter referred to as the “Plaintiff ○○○○”) and ○○○○○ Development Co., Ltd. (hereinafter referred to as the “○○○○○○○○”) purchased forest land, etc. as a number of lots, divided them into salt, divided them into several lots, and then sold them through telecomter to many and unspecified persons. The above companies constitute a planning real estate company with all of them established by making investments in this full amount of ○○○○○○, and a special person as defined in Article 87(1) of the Enforcement Decree of the Corporate Tax Act.
B. The Plaintiff 1: (a) total of 82,363 square meters of each real estate indicated in the list (attached Form 1); (b) 27 square meters of each real estate listed in the list (hereinafter
In 2,769,861,00 won after acquiring 2,769,861,000 won, from November 30, 2004 to December 29, 2004, 775,686,000 won for transfer loss (=2,769,861,000 won - 775,686,000 won) and filed a return of corporate tax for the year 2004.
② On December 28, 2004, the Plaintiff ○○ acquired a total of 82,650 square meters of each real estate listed in the list (attached Form 2) in KRW 13 parcels of real estate (hereinafter referred to as “attached Form 2 real estate”) in KRW 1,437,419,00, and transferred it to ○○○○○, a special-related party, in KRW 600,809,00, and filed a report on the corporate tax for the year 2004.
③ On December 28, 2004, Plaintiff ○○ acquired a total of 58,667 square meters of each real estate listed in the list (attached Form 3) in KRW 1,410,05,00,000, and transferred KRW 523,276,00 to ○○ Industry, a special-related person, and filed a report on the corporate tax for the year 2004. (i.e., KRW 1,410,054,000 (= KRW 523,276,00).
(4) The reorganization thereof shall be as follows (units: ,00 won):
A taxpayer (Plaintiff)
Transferred Real Estate
Number of parcels
Area (Size)
(1) Acquisition value:
(2) Transfer value
Transfer loss (1-2)
( principal)○○○○○○
Attached 1 Real Estate
27
82,363
2,769,861
75,686
1,994,175
(m)○○ Investment Information
Attached 2 Real Estate
13
82,650
1,437,419
600,809
836,610
○○ Comprehensive (State)
Attached 3 Real Estate
65
58,667
1,410,054
523,276
86,778
Total
105
23,680
5,617,334
1,899,771
3,717,563
C. On June 23, 2005, the Commissioner of the National Tax Service conducted a tax investigation with respect to the Plaintiffs and ○○○○○○○○○○○, and intended to impose tax on the grounds that the Plaintiffs transferred attached 1, 2, and 3 real estate (hereinafter “instant real estate”) at a price lower than the market price to ○○○○○, a special-related party, and subsequently unjustly reduced corporate tax. The Plaintiffs transferred the ownership registration and the settlement of the price was completed, and the Plaintiffs returned the ownership of the instant real estate remaining after the ○○○○○○○○ transferred to many and unspecified persons (hereinafter the Plaintiff’s future 69,753 square meters, ○○○○○, 79,675 square meters, and 35,508 square meters) from August 1, 2005 to August 23, 2005.
D. In order to avoid corporate tax due to the denial of wrongful calculation, the Commissioner of the ○○○○○○○ upon the Plaintiffs’ commencement of tax investigation, the Plaintiffs had to lawfully transfer ownership registration and complete the settlement of price in accordance with the original transfer contract, and deemed that the tax relationship that was effective due to the fulfillment of the taxation requirements following the transfer of the instant real estate was arbitrarily changed by the party’s ex post facto agreement, and thus, the Plaintiffs did not recognize the cancellation of the ex post facto agreement. The Plaintiffs deemed that the instant real estate was transferred to ○○○○, which is a person with special relationship, lower than the market price (sale case price or acquisition price) and notified the Defendants of the taxation data by applying the provision on the denial of wrongful calculation under Article 52 of the Corporate Tax Act by deeming that the instant real estate was transferred to ○○○○, which is a person with special relationship, the market
E. (1) On April 1, 2006, the head of the Defendant ○○○ Tax Office: (a) deemed that the market price at the time of the transfer of real estate attached to the Plaintiff’s future is KRW 3,545,529,000 at the time of the transfer of real estate attached to the Plaintiff’s future (in case of the land that is confirmed by transfer to many and unspecified persons through the teleatter, the acquisition value in the Plaintiff’s future is considered as the market price; and (b) imposed KRW 1,31,493,184,184 for the corporate tax belonging to the year 2004 by including the difference between the transfer value already reported to the Plaintiff and the transfer value of KRW 775,686,00 in the market price; and (c) the transfer value of the real estate already reported in the market
② On April 1, 2006, the head of the Defendant○○ Tax Office: (a) deemed the market price of KRW 2,546,450,00 at the time of the transfer of real estate attached to attached Table 2 to the Plaintiff ○○○ on KRW 2,546,450,00 (with respect to the land where the transaction example is confirmed by transferring it to many and unspecified persons via the teleatter, the acquisition value of Plaintiff ○○○ was considered as the market price; and (b) imposed tax amount of KRW 1,945,641,00 and other research output amount of KRW 2,770,124,00,000 for the transfer value already reported, and imposed tax of KRW 1,65,603,631 for the year 204.
③ On April 1, 2006, the head of the Defendant○○ Tax Office: (a) deemed the market price of KRW 6,794,750,000 at the time of transfer of real estate attached to attached Table 3 to Plaintiff ○○○ on April 1, 2006 (with respect to the land that was transferred to many and unspecified persons and confirmed by transaction example, the acquisition value of Plaintiff ○○○○ was deemed the market price; and (b) imposed corporate tax of KRW 2,652,826,029 on the land other than the land in which the transaction example was confirmed by transferring it to the unspecified persons through the teleatter; and (c) the difference between the transfer value of KRW 523,276,00 and the transfer value of KRW 6,271,474,641,000 already reported
(4) The vote shall be arranged as follows (unit: 1,000 won):
taxpayer (Plaintiff)
Transferred Real Estate
The reported transfer value (1)
Market price (2) at the time of transfer
Low price transfer (3) in the gross income (2-1)
Other extractive profits (4)
Total sum of earnings (3+4)
( principal)○○○○○○
Attached 1 Real Estate
75,686
3,545,529
2,769,843
955,612
3,725,455
(m)○○ Investment Information
Attached 2 Real Estate
600,809
2,546,450
1,945,641
2,770,124
4,715,765
○○ Comprehensive (State)
Attached 3 Real Estate
523,276
6,794,750
6,271,474
675,641
6,947,115
Total
1,899,771
12,886,729
10,986,958
401,377
15,388,335
F. On June 30, 2006, the plaintiffs filed an appeal with the ○○○ Tribunal on June 30, 2006 as the first imposition disposition, 2006, 2589, 2622, and 2991. The ○○ Tribunal decided on May 16, 2007 that the market price at the time of the transfer of the real estate of this case should be the acquisition price of all the plaintiffs and revised the reduction. Accordingly, on June 13, 2007, the head of the ○○ Tax Office revised the first imposition disposition against the plaintiff on June 13, 2007 as KRW 1,273,475,316, respectively. The defendant ○○ Tax Office revised the first imposition disposition to the plaintiff ○○○ on May 16, 2007 as the first imposition disposition and correction of the tax amount as KRW 526,271,270 after correction (the same shall apply to the first imposition disposition).
(Defendant)
taxpayer (Plaintiff)
Article 1 (Date of Notice)
Article 22 (Date of Reduction or Correction)
Amount of tax remaining after the reduction of adjudication (1-2);
○ Head of tax office
(an)○○○○○○
1,311,493,184 ( April 1, 2006)
274,238,884 ( May 13, 2007)
1,037,254,300
○ Head of tax office
( Note)○○○ Information
1,665,603,631 ( April 1, 2006)
392,128,315 ( May 16, 2007)
1,273,475,316
○ Head of tax office
○○ Comprehensive (State)
2,652,826,029 ( April 1, 2006)
2,090,104,359 ( June 1, 2007)
562,721,670
Total
3 enterprises
5,629,922,844
2,756,471,558
2,873,451,286
[Grounds for Recognition] Unsatisfy, Gap1-6 each entry (including a branch number)
2. Whether the instant disposition is lawful
A. The plaintiffs' assertion
(1) The Plaintiffs’ transfer of the instant real estate to ○○○ was aimed at efficiently carrying out business by integrating the existing organizations and projects through liquidation of the Plaintiffs, but, with the knowledge that the original purpose cannot be achieved after the transfer of the instant real estate, exercised the right of revocation on the grounds of mistake in the important part of a juristic act pursuant to Article 109(1) of the Civil Act, with the knowledge that the original purpose cannot be achieved after the transfer of the instant real estate. Therefore, the instant disposition was unlawful inasmuch as the transfer of the instant real estate, which is the tax basis,
(2) At the time of acquiring the instant real estate from the Plaintiffs, ○○○○○○ (hereinafter “○○○”) exempted the Plaintiffs from liability and agreed to succeed to the employment of employees, but ○○○ (hereinafter “○○○○”) failed to implement the above agreement. Accordingly, the Plaintiffs cancelled the transfer contract by exercising the right to rescind the agreement due to nonperformance, and reinstate the ownership in the name of the Plaintiffs by cancelling the registration of transfer of ownership, and thus, the instant real estate transfer act was retroactively extinguished, and thus, the instant disposition was unlawful.
(3) The Plaintiffs and ○○○○○ rescinded a transfer agreement, and accordingly, ○○○○ cancelled the registration of ownership transfer on the instant real estate, thereby restoring ownership in the Plaintiffs’ name by cancelling the registration of ownership transfer on the instant real estate. Since the transfer transaction of the instant real estate was retroactively terminated due to the cancellation of agreement by the parties, the instant disposition is unlawful.
(4) Even if the Plaintiff’s transfer of the instant real estate was conducted at a lower price, the Plaintiff’s transfer of the instant real estate to the lower price was to bear all the costs associated with the creation of the project site in the future. The instant real estate is difficult to sell the real estate, and is a malicious stock real estate with a lower property value, and there is justifiable reason that it was an additional burden of fixed costs arising from the possession of the inventory real estate, and thus, cannot be deemed to be an abnormal low-price transfer that lacks economic rationality. Furthermore, the Plaintiffs and ○○○○○ constitutes a single entity economically in its substance, and thus, even if the transfer was conducted at a low price, there is no abstract risk of tax avoidance, and in fact, there was no specific risk of tax avoidance or tax avoidance. Therefore, the instant disposition was
(b) the relevant regulations;
○ Declaration of Intention due to Mistake under Article 109 of the Civil Code
(1) A declaration of intention may be cancelled when there is an error in the contents of a juristic act in its essential part: Provided, That such a mistake may not be cancelled if it was caused by the gross negligence of the seal.
Article 40 of the Corporate Tax Act for Business Year of Profit and Loss
(1) The fiscal year of accrual of earnings and losses of a domestic corporation shall be the fiscal year to which the date on which the concerned earnings and losses are determined belongs.
(2) Matters necessary for the scope of the fiscal year of accrual of earnings and losses under the provisions of paragraph (1) shall be prescribed by Presidential Decree.
○ Denial of wrongful calculation under Article 52 of the Corporate Tax Act
(1) Where the head of the district tax office having jurisdiction over the place of tax payment or the Commissioner of the competent Regional Tax Office deems that the tax burden of a domestic corporation has been unjustly reduced through transactions with persons with a special relationship prescribed by Presidential Decree (hereinafter referred to as "specially related persons"), he/she may calculate the amount of income for each business year of the relevant corporation regardless of the activities or calculation of the amount of income of the relevant corporation (hereinafter
(2) In the application of the provisions of paragraph (1), the standard for determination shall be the prices applied or to be applied in sound and generally accepted practices and normal transactions between persons without a special relationship (including rates, interest rates, rents, exchange rates and other equivalent rates; hereafter referred to as "market price" in this Article).
(4) In applying the provisions of paragraphs (1) through (3), matters necessary for the types of wrongful calculation and the assessment of market price shall be prescribed by the Presidential Decree.
Article 68 of the Enforcement Decree of the Corporate Tax Act for Business Year
(1) In the application of the provisions of Article 40 (1) and (2) of the Act, the fiscal year of accrual of gross income and deductible expenses due to the transfer of assets shall be the fiscal year which includes the date under each
1. For the sale of commodities (excluding real estate), manufactured goods, or other products (hereafter in this Article.. the same shall apply): The date on which the commodities are delivered;
2. For the trial sale of commodities: The date on which the other party expresses the intention to purchase the commodities: Provided, That where the sale is confirmed by a special contract which states that if the commodities are not returned or the intention to refuse them is not expressed within a certain period, it shall be the date of the expiration
3. Transfer of assets other than commodities, etc.: The date the price is settled: Provided, That where registration of transfer of ownership, etc. (including registration) is filed before the price is settled, or where the other party delivers the relevant assets or uses and benefits from the relevant assets, the date of registration of transfer (including the date of registration). The date of delivery or use and profit-making is earlier;
Article 87 of the Enforcement Decree of the Corporate Tax Act
(1) "Person with a special relationship prescribed by Presidential Decree" in Article 52 (1) of the Act means a person with a relationship falling under any of the following subparagraphs with a corporation (hereinafter referred to as a "person with a special relationship"):
1. Persons recognized as exercising real influence over the operations of the concerned corporation, such as exercising the right to appoint officers or determining the course of business (including persons to be treated as directors under Article 401-2 (1) of the Commercial Act) and their families;
4. Other corporations which invest 30/100 or more of the total number of stocks issued or total amount of investment by a person falling under subparagraphs 1 through 3. Article 88 (Calculation Type, etc. of Wrongful Acts)
(1) "Where it is deemed that the tax burden has been unjustly reduced" in Article 52 (1) of the Act means cases falling under any of the following subparagraphs:
1. Where assets are purchased or received as investments in kind at a price above the market price or the assets are excessively depreciated;
3. Where assets are transferred or invested as investment in kind with no compensation or at a price below the market price. Article 89 (Scope of Market Price, etc.)
(1) In the application of the provisions of Article 52 (2) of the Act, if there is a price generally traded with many and unspecified persons other than a person with a special relationship or between a third party who is not a person with a special relationship in a similar situation to the concerned transaction,
(2) In applying Article 52 (2) of the Act, if the market price is unclear, the amount calculated by applying in sequence the following subparagraphs:
1. Where an appraisal corporation under the Act on the Public Notice of Land Prices and the Evaluation of Land, etc. has a value, that value: Provided, That stocks, etc. shall be excluded;
2. The amount appraised by the mutatis mutandis application of the provisions of Articles 38 through 39-2, and 61 through 64 of the Inheritance Tax and Gift Tax Act.
(5) In cases falling under the calculation of unjust acts under the provisions of Article 88, the amount of income for each business year of the concerned corporation shall be calculated by adding the difference, etc. in the market price under the provisions of paragraphs (1) through (4) to the gross income under the provisions of Article 52
Article 61 of the Inheritance Tax and Gift Tax Act: Appraisal of Real Estate
(1) Real estate shall be appraised by the following methods:
1. Land:
The individual standard market price under the Act on the Publication of Land Prices and the Evaluation of Land, etc. (hereinafter referred to as the "individual standard market price").
C. Determination
(1) In order to cancel a legal act on the ground that the motive mistake falls under an error in an important part of the contents of a legal act, it is sufficient to indicate the motive to the other party as the content of the pertinent declaration of intent, and it is sufficient to conclude that the other party is an object of a legal act in the interpretation of an expression of intent, and it is not necessary to reach an agreement between the parties to separately consider the motive as the content of a legal act. However, the mistake in the contents of the legal act should be an important part to the extent that it would have been deemed that the general public would not have made such an expression of intent (see Supreme Court Decision 200Da12259, May 12, 2005).
Although the plaintiffs asserted that the transfer contract of this case was cancelled on the ground of mistake with the knowledge that it was impossible to achieve the purpose of liquidation, according to the statements in Eul 12, Eul 13, Eul 18-1, Eul 18-1, and Eul 20, and witness's testimony at the time of the above tax investigation, it can be recognized that ○○ stated that the transfer of the real estate of this case was for the purpose of tax evasion. In light of this, it is insufficient to recognize that the evidence submitted by the plaintiffs alone was erroneous in the important part of the transfer contract of this case, or that the plaintiffs revoked the transfer contract of this case on the ground thereof, and there is no other evidence to acknowledge this otherwise,
(2) The plaintiffs asserted that ○○ Industry exercised the right to rescind an agreement because it did not perform the matters under the special agreement for transfer (the succession of employment by the parties and employees exempt from liability), and that the act of transferring the real estate of this case has become null and void retroactively. The plaintiffs' assertion is insufficient to recognize that the plaintiffs exercised the right to rescind an agreement solely on the grounds that the plaintiffs failed to perform the matters under the special agreement for transfer of ○○ Industry (the succession of employment by the parties and employees exempted from liability), and there is no other evidence to prove otherwise.
(3) The Plaintiffs asserts that the instant real estate transfer act becomes null and void retroactively due to the rescission of an agreement. On the other hand, since the tax claim relationship is determined by the law as to the requirements for establishment and the procedure for realization, if the taxation requirements as prescribed by each tax law are met, the tax obligation is established, and once established, the tax obligation cannot be changed in principle, and the change in circumstances after the establishment of the tax obligation does not extend retroactively to the tax claim. As such, it is reasonable to view that the change in the tax claim relationship in accordance with a contract between private persons is not recognized in principle as a matter of principle.
As to the instant case, inasmuch as the Plaintiffs’ tax liability becomes effective by transferring the instant real estate to ○ industry, which is a person with a special relationship, and completing not only the settlement of price but also the transfer of ownership, the agreement on the cancellation of the instant transfer contract asserted by the Plaintiffs should be deemed a new agreement with the purport that the Plaintiffs would return the registration of ownership transfer of the instant real estate to the Plaintiffs. As such, aside from the fact that the said agreement takes effect in the future between the parties, its effect is not retroactive to the time of the conclusion of the instant transfer contract (i.e., the Plaintiff’s assertion that the transfer transaction of the instant real estate is retroactively extinguished due to the cancellation of the agreement by the parties concerned), if the tax law relationship, which was already established as effective due to the fulfillment of the taxation requirement, is a result of approving the act of tax avoidance that may be exempted
Therefore, the plaintiffs cannot dispute the illegality of the disposition of this case on the premise that the contract of this case terminated retroactively by the termination of agreement. Therefore, the plaintiffs' assertion is without merit.
(4) In light of the following: (a) comprehensively taking account of the entries in B 12, 17-1, 2, and 23-1, and 23-1 and 2; (b) the testimony of the witness ○○○○-1 and 2; and (c) the overall purport of the pleadings, the Plaintiffs selected and confirmed a project site where land price increase is anticipated; and (d) took various measures to sell it to customers in line with the demand of the customers; (b) transfer part of the instant real estate acquired from the Plaintiffs at a price higher than the acquisition price to unspecified multiple customers over a short period; and (c) transfer of the instant real estate at a low price with the intent to avoid taxes on the transfer transaction of the instant real estate at the time of transfer, the market price at the time of the transfer of the instant real estate shall be deemed to be at least acquisition price; and (d) the Defendants were deemed to have transferred the instant real estate at a lower price than the market price at the time of transfer of the instant real estate at the
3. Conclusion
Therefore, the plaintiffs' claims of this case are dismissed as it is without merit. It is so decided as per Disposition.
[Attachment 1]
Plaintiff
○○ Transfer Real Estate List Corporation
(units: 1,00 won
Order
Lot Number of Location
Area of a square meter;
Acquisition Value
Transfer Value
Market Price
1
○○○○○○○○○○○○○○○○○○○
496
17,254
7,100
82,500
2
○○○○○○○○○○○○○○○○○○○
662
23,029
9,460
10,000
3
○○○○○○○○○○○○○○○○○○○
662
23,029
9,460
10,000
4
○○○○○○○○○○○○○○○○○○○
662
23,029
9,460
10,000
5
○○○○○○○○○○○○○○○○○○○
539
18,750
7,710
89,650
6
○○○○○○○○○○○○○○○○○○○
826
28,734
11,837
137,500
7
○○○○○○○○○○○○○○○○○○○
826
28,734
11,837
137,500
8
○○○ ○○ ○○ ○○ ○○○○
56
10,500
3,728
3,600
9
○○○ ○○ ○○ ○○ ○○○○
1,243
23,500
8,331
82,720
10
○○○ ○○ ○○ ○○ ○○○○
92
18,750
6,650
66,000
11
○○○ ○○ ○○ ○○ ○○○○
661
12,500
4,431
44,000
12
○ ○○ ○○ ○○ ○○ ○○
7,141
143,639
36,485
143,640
13
○○○ ○○ ○○ ○○ ○○ ○○ ○○ ○○
2,933
89,852
2,823
89,853
14
○○○○○○○○○○○○○○○○○○○
24,793
644,997
169,830
645,000
15
○○○○○○○○○○○○○○○○○○○
13,224
496,000
125,984
496,000
16
○○○ ○○ ○○ ○○ ○○ ○○ ○○ ○○
288
13,615
4,194
13,615
17
○○○○○○○○○○○○○○○○○○○○
3,722
93,232
23,682
93,232
18
○○○ ○○ ○○ ○○ ○○○
1,307
73,074
18,562
73,075
19
○ ○○ ○○ ○○ ○○ ○○
436
25,733
6,537
25,733
20
○○ ○○ ○○ ○ ○○ ○○ ○○ ○○ ○○
2,975
127,890
45,000
127,890
21
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
2,977
175,702
44,628
175,702
22
○○ ○○ ○○ ○ ○○ ○○ ○○ ○○ ○○
2,314
54,880
34,672
54,880
23
○○ ○○ ○○ ○ ○○ ○○ ○○ ○○ ○○
3,306
174,900
44,425
174,900
24
○○ ○○ ○○ ○ ○○ ○○ ○○ ○○ ○○
2,149
137,99
35,062
138,000
25
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
722
42,139
10,704
42,139
26
○○○ ○○ ○○ ○○ ○○○○
5,455
27,700
57,835
27,700
27
○○○ ○○ ○○ ○○ ○○○○
496
20,700
5,259
20,700
Combined (27 parcels)
82,363
2,769,861
75,686
3,545,529
[Attachment 2]
○○ Investment Information Transfer Real Estate List Co., Ltd.
(units: 1,00 won
Order
Lot Number of Location
Area of a square meter;
Acquisition Value
Transfer Value
Market Price
1
○○○○○○○○○○○○○○○○○○○
1,765
79,515
31,508
267,000
2
○○○○○○○○○○○○○○○○○○○
92
44,692
17,710
150,000
3
○○○○○○○○○○○○○○○○○○○
807
36,357
14,408
122,000
4
○○○○○○○○○○○○○○○○○○○
92
44,692
17,710
150,000
5
○○○○○○○○○○○○○○○○○○○
92
44,692
17,710
150,000
6
○○○○○○○○○○○○○○○○○○○
331
14,912
5,910
50,000
7
○○○○○○○○○○○○○○○○○○○
92
44,692
17,710
150,000
8
○○○○○○○○○○○○○○○○○○○
92
44,692
17,710
150,000
9
○○○○○○○○○○○○○○○○○○○
1,035
46,625
18,476
156,500
10
○○○ ○○ ○○ ○○ ○○○○
1,983
12,600
5,292
102,000
11
○○ ○○ ○○ ○ ○○ ○○ ○○ ○○ ○○
1,653
5,000
7,552
80,000
12
○○○○○○○○○○○○○○○○○○○
1,253
18,950
7,959
18,950
13
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
68,863
1,000,000
421,154
1,000,000
Combined (13 parcels)
82,650
1,437,419
600,809
2,546,450
[Attachment 3]
○ List of Transfered Real Estate Co., Ltd.
(units: 1,00 won
Order
Lot Number of Location
Area of a square meter;
Acquisition Value
Transfer Value
Market Price
1
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
416
8,303
3,048
44,100
2
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
3,275
65,385
23,986
346,850
3
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
866
17,289
6,345
91,700
4
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
510
10,149
3,737
53,900
5
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
617
12,323
4,521
65,450
6
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
930
18,517
6,814
98,350
7
○○○○○○○○○○○○○○○○○○○
430
8,584
2,151
45,500
8
○○○○○○○○○○○○○○○○○○○
1,301
25,964
9,530
137,900
9
○○○○○○○○○○○○○○○○○○○
894
17,793
6,550
94,500
10
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,054
21,043
7,720
111,650
11
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,127
22,472
8,255
19,350
12
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
92
19,805
7,268
105,000
13
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
64
1,277
7,735
111,650
14
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
927
18,452
6,792
98,000
15
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
958
19,126
7,019
101,500
16
○○○○○○○○○○○○○○○○○○○
858
17,134
6,286
91,000
17
○○○○○○○○○○○○○○○○○○○
595
11,862
4,359
63,000
18
○○○○○○○○○○○○○○○○○○○
91
19,770
7,261
105,000
19
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
802
16,011
5,876
85,050
20
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
823
16,431
6,030
87,150
21
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
924
18,452
6,770
98,000
22
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
676
13,443
4,953
71,400
23
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
745
14,827
5,458
78,750
24
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
919
18,320
6,733
97,300
25
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
905
18,056
6,631
95,900
26
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,037
20,703
7,595
109,900
27
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
663
13,236
4,858
70,350
28
○○○○○○○○○○○○○○○○○○○
735
14,629
5,385
7,700
29
○○○○○○○○○○○○○○○○○○○
752
14,959
5,510
79,450
30
○○○○○○○○○○○○○○○○○○○
804
16,014
5,891
85,050
Order
Lot Number of Location
Area of a square meter;
Acquisition Value
Transfer Value
Market Price
31
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,513
30,207
11,083
160,300
32
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,177
23,498
8,620
124,600
33
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,548
30,905
11,340
163,800
34
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,078
21,483
7,865
114,100
35
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
922
18,407
6,755
97,650
36
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,117
22,300
8,182
18,300
37
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
1,513
30,207
11,083
160,300
38
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
600
11,979
4,396
63,700
39
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
560
11,137
4,103
59,150
40
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
927
18,452
6,792
98,000
41
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
927
18,452
6,792
98,000
42
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
661
13,180
4,843
98,000
43
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
592
11,796
4,337
62,650
44
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
928
18,518
6,799
98,350
45
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
984
19,638
7,209
104,300
46
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
922
18,419
6,755
97,650
47
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
92
19,805
7,268
105,000
48
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
92
19,805
7,268
105,000
49
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
92
19,805
7,268
105,000
50
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
92
19,805
7,268
105,000
51
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
92
19,805
7,268
105,000
52
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
661
13,203
4,843
70,000
53
○○○ ○○ ○○ ○○ ○○○ ○○ ○○
828
16,504
6,052
87,500
54
○○○ ○○ ○○ ○○ ○○ ○○ ○○ ○○
645
37,071
9,630
136,500
5
○○○○○○○○○○○○○○○○○○○
331
14,490
5,450
50,000
56
○○○○○○○○○○○○○○○○○○○
777
34,081
12,794
17,500
57
○○○○○○○○○○○○○○○○○○○
1,110
48,687
18,273
168,000
58
○○○○○○○○○○○○○○○○○○○
1,110
48,687
18,273
168,000
59
○○○○○○○○○○○○○○○○○○○
1,110
48,687
18,273
168,000
60
○○○○○○○○○○○○○○○○○○○
118
5,175
1,943
18,000
61
○○○○○○○○○○○○○○○○○○○
118
5,175
1,943
18,000
62
○○○○○○○○○○○○○○○○○○○
1,110
48,687
18,273
168,000
63
○○○○○○○○○○○○○○○○○○○
1,110
48,687
18,273
168,000
64
○○○○○○○○○○○○○○○○○○○
1,110
48,687
18,273
168,000
65
○○○○○○○○○○○○○○○○○○○
1,010
44,301
16,625
153,000
Combined (65 parcels)
58,667
1,410,054
523,276
6,794,750