6. Avoiding double taxation on dividend income

a. In case of a holding company

Dividend income received by a holding company established in accordance with

Anti-trust and Fair Trade Law from its subsidiaries is not recognized as gains to a

certain extent as the following table shows.

Type of subsidiary

proportion of shares of

proportion of exclusion

subsidiaries owned by

of gains

their holding company

Non-listed corporation

100%

above 80%

90%

50% ~ 80%

60%

Listed corporation

above 40%

90%

30% ~ 40%

60%

b. In case of a corporation other than holding companies

Dividend income received by a corporation other than holding companies from its

subsidiaries is not recognized as gains to a certain extent as shown below.

Type of subsidiary

proportion of shares of

proportion of exclusion

subsidiaries owned by a

of gains

corporation other than

holding companies

Non-listed corporation

100%

above 50%

50%

50% or below 50%

30%

Listed corporation

above 30%

50%

30% or below 30%

30%