Securities Transaction Tax Act Article 2-3

Issuers with the call (put) warrants approved by the competent authority, who sell stocks from the warrant hedging account for quotation obligation and risk management purposes, and whose daily transaction amounts fall within the necessary hedging range, shall be taxed at the rate of 0.1%. This tax rate will apply instead of the provisions set out in Subparagraph 1, Article 2 and the preceding article, within five years from the effective date of this article. However, when selling the underlying stocks to the warrant holder at the contracted exercise price, they shall be subject to the tax rate specified in Subparagraph 1, Article 2 or the preceding article.Regulations governing the requirements for fulfilling quotation obligations and risk management purposes, the criteria for determining the scope, the necessary scope for hedging, internal control, and other related matters referred to in the preceding paragraph shall be prescribed by the Ministry of Finance (hereinafter referred to as the MOF) in consultation with the Financial Supervisory Commission.