Article 1 (Purpose) The Defendant (hereinafter referred to as “A”) shall appoint the Plaintiff (hereinafter referred to as “B”) as a service provider institution in connection with the commission of tax services and enter into this contract to determine matters concerning the scope, terms, etc. of the services.

Article 2 (Commissioning Services) A shall, at the request of A, act on behalf of the following duties:

- The Seoul Regional Tax Office’s duty to fully or partially reduce the tax risk (limited to the pre-announcement of taxation) of “Corporate Tax related to gains on transfer of real estate from the sale of land and buildings located in Bocheon-si 2018, Chungcheongnam-si, Chungcheongnam-si, 201” (see, e.g., Supreme Court Decision 55,070,928, Jul. 1, 2014), including local income tax, at the time of the pre-announcement of taxation (see, e.g., Supreme Court Decision 55,070,928, Jul. 1, 2014) - Other duties deemed necessary to resolve or reduce the risks of corporate tax assessment as set forth in Article 3(Remuneration for Services) ①

* The term “reduction time” in the foregoing Schedule means when the tax authorities are deemed to have made a prior notice of taxation or a decision not to pay taxation.

C. The Supreme Court (Supreme Court Decision 2012Du690 Decided February 28, 2013) held that: (a) the Defendant’s service performance of the reserve fund for essential business was reflected in Article 29(2)5 of the Corporate Tax Act; and (b) the Defendant acquired the real estate used for profit-making business by transferring the reserve fund for essential business to the account for profit-making business after returning the reserve fund to the account for profit-making business; and (c) the tax authority imposed the tax on the amount used as the fund for acquisition of assets used for profit-making business on the ground that the transfer to the account for profit-making business was merely nominal; and (d) the taxation was lawful; and (e) the Defendant acquired the real estate used for profit-making business from the income for profit-making business, but returned the real estate