2. The costs of lawsuit shall be borne by the Plaintiff.

A. The Plaintiff, as a bank established under the Industrial Bank of Korea Act, owns a building 240 located in Gwangju Mine-gu, and has the mining branch of the Industrial Bank of Korea and the second floor of the building, the Bank of Korea's regional headquarters in Honam-Nam.

B. On May 20, 2015, the Defendant conducted a tax investigation with respect to the Plaintiff, and as a result, deemed the above mine branch, Honam District Headquarters, Chungcheongnamnam District Headquarters, Chungcheong/Namnam Business Headquarters as a single business office on July 14, 2015 as a single business office.

1. Each resident tax (including additional tax) imposed a pro rata employee portion as indicated in the disposition of imposition (hereinafter “instant disposition”).

C. On July 31, 2015, the Plaintiff paid a total of KRW 105,271,500 to the employees’ resident tax.

On October 8, 2015, the Plaintiff dissatisfied with the instant disposition and filed a tax appeal against the Defendant with the Tax Tribunal. However, the Tax Tribunal dismissed the decision on March 2, 2017.

[Reasons for Recognition] Facts without dispute, entry of Gap 1, 2, 14 evidence (including a serial number; hereinafter the same shall apply) and the purport of the whole pleadings

2. The advertisement shall be made against the main claim; and

A. In calculating the number of employees, the Defendant asserted that the Plaintiff calculated the number of employees, based solely on the Plaintiff’s wage ledger, determined the number of employees, and imposed the resident tax (including additional tax) including the number of employees on the number of employees to ① a leave of absence, a waiting person for retirement, a soldier’s leave (hereinafter “child leave, etc.”) and ② a person in charge of cooking in a dormitory in another place of business and an employee apartment house (hereinafter “workers in other places of business”).

(1) However, there is no worker temporarily retired from office since the past to the present, and thus, it does not correspond to the human facilities of the headquarters in South Korea (limited to the employees of a place of business who worked at the time of the issuance of childcare leave, etc.). (2) The other place of business provides labor at other places of business, not the headquarters in South Korea, so it is not an employee of the headquarters in South Korea.