Cross-shareholdings between companies entail different legal consequences under Paragraph 2 of Article 179 and Article 369-10 of the Company Act. According to said Paragraphs 2 of Article 179, "the shares held by a company in another company that holds the majority of the voting shares or capital contribution of the former company" and "the shares held by a company in other companies that are affiliated companies and that hold in aggregate, directly or indirectly, the majority of the shares or capital contribution of the former company with voting rights" cannot have any voting rights. However, under Article 369-10, for companies that invest in each other with knowledge of such a fact, their voting rights in the other company cannot exceed one-third of the total voting shares or capital contribution of that company; provided, however, the shares distributed through capitalization of earnings or legal reserves may still have voting rights.

On August 4, 2011, the Ministry of Economic Affairs issued a directive, stating that Paragraph 2, Article 179 would prevail over Article 369-10 under these circumstances. For example, if Company A holds more than 50% of Company B's shares and Company B holds certain shares in Company A, Company B, according to Sub-Paragraph 2, Paragraph 2, Article 179 of the Company Act, will not be entitled to the voting rights attached to its shares in Company A.