All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined.

1.(a)

Article 7(1) of the former Restriction of Special Taxation Act (amended by Act No. 13560, Dec. 15, 2015; enacted on January 1, 2016; and amended by Act No. 14390, Dec. 20, 2016; hereinafter the same) provides that, with respect to a small or medium enterprise that runs a manufacturing business (e) which is a type of business eligible for reduction or exemption among small or medium enterprises, a small enterprise prescribed by Presidential Decree is entitled to the reduction or exemption of an amount equivalent to tax calculated by multiplying the income tax, etc. on income accrued from the relevant place of business by 20/100 of the reduction or exemption rate (subparagraph 2 (b)) in cases of a place of business that runs a manufacturing business in the Seoul Metropolitan area until the taxable year ending on or before December

(hereinafter “Special Tax Reduction and Exemption for Small and Medium Enterprises.” According to Article 6(5)1 of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 26959, Feb. 5, 2016) upon delegation, “small enterprises engaged in manufacturing business as their main business” among “small enterprises prescribed by Presidential Decree” subject to reduction and exemption from special tax on small and medium enterprises refers to small and medium enterprises whose number of employees are continuously employed by the relevant enterprise and whose sales are less than 100 and whose sales are less than 10 billion won.

Article 6(5) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 26959, Feb. 5, 2016) provides that “small enterprises prescribed by Presidential Decree” among the previous provisions shall be construed as “small enterprises whose sales volume among small and medium enterprises is within the standard of size calculated by applying the attached Table 3 of the Enforcement Decree of the Framework Act on Small and Medium Enterprises mutatis mutandis.” [Attachment 3] subparagraph 27 of the former Enforcement Decree of the Framework Act on Small and Medium Enterprises (amended by Presidential Decree No. 28378, Oct. 17, 2017) shall be construed as “small and medium enterprises that mainly engage in the manufacturing business of other products.”