The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. As to the grounds of appeal Nos. 1 and 2

A. The substance over form principle under Article 14(1) of the Framework Act on National Taxes, in cases where there is a separate person to whom the income, profit, property, transaction, etc. belongs differently from the nominal person, the nominal person is not the person to whom the property belongs, but the person to whom the property belongs. Thus, in cases where the nominal person is not the person to whom the property belongs, and there is another person who substantially controls and manages the property through the control, etc. over the nominal person, and the disparity between the nominal person and the substance arises from the purpose of tax evasion, the income on the property shall be deemed to be attributed to the person to whom the property is substantially controlled and managed, and such principle shall be deemed to be the person to whom the income on the property belongs, and it shall be applied as it is, unless

(See Supreme Court Decision 2011Du3159 Decided April 11, 2013, etc.). B.

The lower court: (1) The International Peasum Inc. (hereinafter referred to as the “IP”) held 100% of the shares and established for the purpose of investing in the oil-related projects among the countries of the world as the United Nations of America; (2) IPIC holds 100% of the shares issued by the Plaintiff, who is a Finland corporation, and holds 75.9% of the shares issued by the Plaintiff, who is the Netherlands corporation, and IPIC holds 24.1% of the remaining shares issued by the Plaintiff; and (3) on August 12, 2010, the Plaintiff is Hyundai Heavy Industries Co., Ltd. (hereinafter referred to as the “Nean Industries”).