2. The Defendant’s corporate tax of May 28, 2010 against the Plaintiff on May 28, 2014 523,498.

A. The summary of the party's argument, 1) the plaintiff's argument, 2) the defendant's argument;

B. In addition to the addition or dismissal of a part of the following, the pertinent part of the reasoning of the judgment of the court of first instance is identical to the corresponding part of the reasons for the judgment of the court of first instance (from heading 5 to 10, and from 16 to 22). As such, this part shall be cited pursuant to Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Parts that vary from the judgment of the first instance court;

C. Article 57(3) of the Corporate Tax Act provides that “The amount equivalent to the tax amount reduced or exempted for the pertinent income generated from overseas sources by a domestic corporation which has income from overseas shall be deemed the amount of foreign corporate tax subject to the tax credit or inclusion in deductible expenses under paragraph (1) within the scope prescribed by the relevant tax treaty”, as well as the amount equivalent to the tax amount reduced or exempted for the pertinent income generated from overseas sources in the country of the other country under the relevant tax treaty.”

In addition, Article 23(1) of the Korea-China Tax Treaty is "in the case of a Korean resident, double taxation shall be avoided as follows:

Subject to the provisions of the Korean tax law regarding the tax credit granted for Korean tax payable in countries other than Korea, the Korean tax credit shall be granted, either directly or through mutual aid for the source income in China, and the Chinese tax payable in accordance with the Chinese law and this Agreement shall be granted from the Korean tax payable for that income.

However, the deductible tax amount is the proportion of the source income in China to the total income subject to Korean tax payment.