□ Participation in the comprehensive share exchange
The comprehensive share exchange is expected to qualify as an eligible comprehensive share exchange pursuant to Article 38(1) of the Restriction of Special Taxation Act. Accordingly, for corporate shareholders and major individual shareholders participating in the transaction, tax deferral is expected to apply, and securities transaction tax is expected to be exempted.
In addition, although the comprehensive share exchange involving resident minority individual shareholders constitutes an off-market transaction, capital gains tax is not imposed pursuant to Article 94(1)3(a) of the Income Tax Act, and, as the transaction is expected to qualify as an eligible comprehensive share exchange, securities transaction tax is also expected to be exempted.
□ Exercise of appraisal rights
In the event appraisal rights are exercised, resident individual shareholders who do not qualify as major shareholders under the Income Tax Act will not be subject to capital gains tax on gains arising from the comprehensive share exchange.
However, if a shareholder qualifies as a major shareholder pursuant to Article 157 of the Enforcement Decree of the Income Tax Act, capital gains tax may be imposed on gains realized from the transfer in accordance with Article 94 of the Income Tax Act.
Whether taxes apply may vary depending on each shareholder’s individual circumstances, including the number of shares held, acquisition cost, and residency status. For further details, please refer to the company’s disclosed "Registration Statement(Comprehensive Exchange or Transfer of Shares)" (IX. Other Matters Necessary for Investor Protection – 9. 그 밖의 투자의사결정에 필요한 사항 – (마) 주식교환으로 인한 과세관계).
Information on the criteria for determining major individual shareholder status is available at the following link: Enforcement Decree of the Income Tax Act Article 157(Scope of Major Stockholders)
□ Participation in the comprehensive share exchange
The comprehensive share exchange is expected to qualify as an eligible comprehensive share exchange pursuant to Article 38(1) of the Restriction of Special Taxation Act. Accordingly, for corporate shareholders and major individual shareholders participating in the transaction, tax deferral is expected to apply, and securities transaction tax is expected to be exempted.
In addition, although the comprehensive share exchange involving resident minority individual shareholders constitutes an off-market transaction, capital gains tax is not imposed pursuant to Article 94(1)3(a) of the Income Tax Act, and, as the transaction is expected to qualify as an eligible comprehensive share exchange, securities transaction tax is also expected to be exempted.
□ Exercise of appraisal rights
In the event appraisal rights are exercised, resident individual shareholders who do not qualify as major shareholders under the Income Tax Act will not be subject to capital gains tax on gains arising from the comprehensive share exchange.
However, if a shareholder qualifies as a major shareholder pursuant to Article 157 of the Enforcement Decree of the Income Tax Act, capital gains tax may be imposed on gains realized from the transfer in accordance with Article 94 of the Income Tax Act.
Whether taxes apply may vary depending on each shareholder’s individual circumstances, including the number of shares held, acquisition cost, and residency status. For further details, please refer to the company’s disclosed "Registration Statement(Comprehensive Exchange or Transfer of Shares)" (IX. Other Matters Necessary for Investor Protection – 9. 그 밖의 투자의사결정에 필요한 사항 – (마) 주식교환으로 인한 과세관계).
Information on the criteria for determining major individual shareholder status is available at the following link: Enforcement Decree of the Income Tax Act Article 157(Scope of Major Stockholders)