1. Revocation of the first instance judgment.

2. Acquisition tax assessed against the Plaintiff on May 18, 2015 is KRW 1,626,623,100, and is assessed against the Plaintiff.

The reasons why the court has partially accepted the judgment of the court of first instance are the same as that of the judgment of the court of first instance.

Except as follows, the main text of Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

A person shall be appointed.

C. Determination ① Article 105(6) of the former Local Tax Act (wholly amended by Act No. 10221, Mar. 31, 2010) provides that “When a person becomes an oligopolistic shareholder by acquiring a corporation’s stocks or shares, such oligopolistic shareholder shall be deemed to have acquired the relevant corporation’s real estate.” Article 120(6)8 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010) (hereinafter “instant reduction or exemption provision”) provides that “Where a person becomes a holding company (including a financial holding company) under the Monopoly Regulation and Fair Trade Act (hereinafter “Fair Trade Act”) or a holding company becomes an oligopolistic shareholder under Article 22(2) of the Local Tax Act by acquiring the stocks of a subsidiary under the same Act or the Financial Holding Companies Act, Article 105(6) of the former Local Tax Act regarding the imposition of deemed acquisition tax shall not apply to such oligopolistic shareholder.

The legislative intent of this case, except for the subject of deemed acquisition tax, is to support corporate restructuring for the rationalization of ownership and management by granting tax benefits on the establishment of a holding company or the conversion of a holding company.

(see, e.g., Supreme Court Decision 2011Du2781, Jan. 23, 2014). If so, even if a holding company under the Fair Trade Act was already established or converted into a holding company under the Fair Trade Act, if a domestic company is newly incorporated into a subsidiary and becomes a holding company in the domestic company, it is still subject to the reduction or exemption clause in the instant case, as in the case of establishing a