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1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
Reasons
1. Details of the disposition;
A. The International Peatum Inc. (hereinafter referred to as the “IPIC”) is a corporation established in accordance with the Abubathy Act of the United States Armed Forces (hereinafter referred to as the “UAE”), and is aimed at investing in the international petroleum-related business in each world while the Abuba Government holds 100% of the share of 100%.
IPR holds 100% of the issued shares of IPRs GmbH (hereinafter referred to as “IPR”) which is a corporation established on 1998 pursuant to the Finland law (hereinafter referred to as “Flagum”) and a corporation established on Austria law (hereinafter referred to as “IPR”) established on 1997.
Pursuant to the Netherlands Act, the Flagum holds 75.9% of the shares issued by Hanocal Herings B.V. (hereinafter “Hancal”), a corporation incorporated on September 27, 1999, and the IPIC holds the remaining 24.1% shares.
The plaintiff is a legal entity established on January 23, 2006 in accordance with the Netherlands Act, and IPIC has 9.93% of the shares issued by the plaintiff, and IPH holdings hold 0.07% of the remainder.
B. On December 99, Hancal acquired approximately KRW 122,541,211 (50% of the total issued shares) of the preferred shares issued by Hyundai Orck Bank Co., Ltd. (hereinafter “Modio Bank”). On August 12, 2010, the Plaintiff acquired approximately KRW 612,70,000 per share of KRW 5,000 (5,000 per share) from Hancal on February 9, 2006, KRW 49,016,485 (20% of the total issued shares; hereinafter “instant shares”). The Plaintiff acquired shares of KRW 220,574,182,50 per share of KRW 4,50 (4,500 per share) from Hyundai Industries Co., Ltd. (hereinafter “Modern Industries”), and the Plaintiff acquired the shares of KRW 75,205,705,750 per share of KRW 20,705 (hereinafter “instant shares”).
C. In accordance with Article 98(1)4 of the former Corporate Tax Act (amended by Act No. 10423, Dec. 30, 2010), Hyundai Heavy Industries equivalent to 10% of the transfer value (73,524,727,500) and 20% of the transfer value.