1. Acquisition tax imposed by the Defendant on the Plaintiff on December 7, 2017, KRW 134,058,580 and special agricultural and fishing villages tax amounting to 11,338,950.

1. Details of the disposition;

A. On January 12, 2015, the Plaintiff was appointed as the representative director of B Co., Ltd. (hereinafter “Co., Ltd.”). On July 13, 2015, the Plaintiff entered that the Plaintiff acquired 5,000 shares (50%) of the instant corporation (50%; hereinafter “instant shares”) and the remainder of 5,00 shares (50%; hereinafter “instant shares”) respectively.

Since then, on November 21, 2016, the Plaintiff acquired 100,000 shares of the instant corporation, which were issued through capital increase with new shares issued (hereinafter “new shares issued via capital increase”).

B. Upon conducting a tax investigation on the instant corporation on September 4, 2017, the Defendant: (a) deemed that the Plaintiff acquired new shares with capital increase on November 21, 2016 and owned 95.45% (i.e., 105,000 shares/110,000 shares) of the total outstanding shares of the instant corporation; (b) deemed that the first oligopolistic shareholder was the oligopolistic shareholder; (c) on December 7, 2017, the Defendant calculated the Plaintiff’s tax assessment and assessment of KRW 5,413,545,723 by multiplying the book value of real estate owned by the instant corporation as of the date of acquisition of new shares with capital increase by the Plaintiff’s ownership ratio pursuant to Article 7(5) of the former Local Tax Act (Amended by Act No. 14474, Dec. 27, 2016; hereinafter the same shall apply); and (d) calculated the acquisition tax and assessment of KRW 167,293,3939,545

(hereinafter “instant disposition”). C.

On February 12, 2018, the Plaintiff appealed against the instant disposition, and filed an appeal with the Tax Tribunal. On June 14, 2018, the Tax Tribunal dismissed the Plaintiff’s appeal.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1, 2, 3, Eul evidence Nos. 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. On January 12, 2015, the Plaintiff asserted by the parties, acquiring the instant legal entity, and thereby, shares of this case.