1. It is confirmed that the Defendant’s attachment disposition against the property listed in the separate sheet No. 1 on December 19, 2014 is invalid.

2...

1. Details of the disposition;

A. The Plaintiff is a company established in around 2001 for the purpose of selling and distributing health foods, cosmetics, and consumer products, wholesale and retail business, etc.

B. On December 19, 2014, the Defendant: (a) seized the Plaintiff’s property (hereinafter “instant property”) listed in the [Attachment 1 List pursuant to Article 98 of the former Framework Act on Local Taxes (amended by Act No. 13293, May 18, 2015) and Article 41 of the National Tax Collection Act in order to collect the amount of delinquent local taxes of KRW 10,947,597,360, including the Plaintiff’s resident tax, etc. in 2006; and (b) notified the Plaintiff of the attachment and compulsory refund of the claim on April 29, 2015.

C. The property of this case is the Plaintiff’s share in the Plaintiff’s limited liability company (hereinafter “instant limited liability company”), the dividend and settlement money to be paid by the said company to the Plaintiff. It is the limited liability company located in C of the People’s Republic of China.

[Ground of recognition] Facts without dispute, entry of Gap 1 and 2 evidence, purport of the whole pleadings

2. Summary of the plaintiff's assertion

A. The Plaintiff’s failure to pay delinquent taxes before receiving the notice of the instant attachment disposition, which served as the ground for the instant attachment disposition, is null and void since the instant attachment disposition is likely to be based on the local tax claim whose tax statute expired.

B. The instant property is within the People’s Republic of China where the Republic of Korea does not have the right to collect, and thus the instant seizure disposition is null and void as it relates to property not subject to seizure under the Framework Act on Local Taxes and the National Tax Collection Act.

C. Since the notice of attachment to the third obligor on the attachment disposition of this case does not contain any provision prohibiting payment to the obligor, the attachment disposition of this case is invalid.

3. Attached Form 2 of the relevant Acts and subordinate statutes shall be as follows;

4. Determination

A. The validity of the taxation disposition, which is the cause of the instant attachment disposition, 1.