1. The part against the plaintiff falling under the following among the judgment of the first instance shall be revoked:

2. The defendant.

1. The reasoning for the court’s explanation on this part is as follows, except for the corresponding part among the judgment of the court of first instance as stated below, and is the same as the entry of “1. Ground for Disposition” as stated in 2-3 of the judgment of the court of first instance. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure

3. The 6th place "(hereinafter referred to as the "disposition of this case") shall be deleted."

3. The following shall be added to the 9th place below:

A person shall be appointed.

F. The Plaintiff, with the purport of seeking revocation by specifying only the part concerning the dividend paid by the Plaintiff to F among the above dispositions, filed a claim for revocation of the disposition of collecting corporate tax of KRW 1,035,727,273 and the disposition of imposing additional tax for failure to withhold taxes of KRW 103,572,727,727 among the above disposition of KRW 1,708,949,90 (including additional tax)

(hereinafter referred to as “instant disposition”)

2. Whether the instant disposition is lawful

A. The reasoning for the court’s argument concerning this part is as stated in the part on “A. Plaintiff’s assertion” as stated in the three pages of the judgment of the court of first instance, except for the corresponding part of the judgment of the court of first instance as follows. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

Under 3, the term “Sweden” shall be deemed to read “Sweden”.

3 under the 3rd below up to the 2rd below the same page, the following shall be met:

Therefore, F is deemed to constitute a beneficial owner under Article 10(2) of the Korea-U.S. Tax Treaty due to the lack of contractual or legal obligation to transfer the instant dividend income to B, and the disparity between name and substance or the purpose of tax avoidance is not recognized. Therefore, the application of the Korea-U.S. Tax Treaty to the instant dividend income under the principle of substantial taxation under the Framework Act

The instant disposition on a different premise is taken.