2.

A. From 2010 to 2012, the Plaintiff owned 60% of the capital of Non-Party Jindo Limited Corporation (hereinafter “instant Chinese subsidiaries”), a Chinese subsidiary, from 2010 to 2012.

B. The Plaintiff reported and paid corporate tax by applying the provisions of foreign tax credit under Article 57 of the former Corporate Tax Act (amended by Act No. 12850, Dec. 23, 2014; hereinafter “former Corporate Tax Act”) to the dividends paid from the instant Chinese subsidiaries from 2010 to 2012 (hereinafter “instant dividends”).

(unit: 20102,267,192,621- 323,884,660- - 321,870,7114 243,477,631,623,623,572,981-1, 20121,874,874,490,28293,724,7293,524,530,094-

C. On November 7, 2013, the Defendant issued a revised notice of the Plaintiff’s KRW 370,789,490 of the corporate tax for the business year 2010, KRW 635,253,810 of the corporate tax for the business year 2011, and KRW 402,243,640 of the corporate tax for the business year 2012, on the grounds that the Plaintiff calculated the amount of indirect foreign tax credit.

(hereinafter “instant increase and correction disposition”) D.

On February 4, 2014, the Plaintiff, who was dissatisfied with the instant disposition of increase and decrease, filed a petition for adjudication with the Tax Tribunal (hereinafter “instant petition for adjudication”), but was partially dismissed on May 20, 2015.

After that, the Plaintiff filed a lawsuit seeking the revocation of the instant disposition for the rectification of increase under this Court 2015Guhap71822 and pending the lawsuit in this Court.

E. On November 11, 2014, the Plaintiff (i) paid the instant dividends to China pursuant to Article 10(2) of the Agreement between the Government of the Republic of Korea and the Government of the People’s Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (hereinafter “instant Tax Treaty”), in addition to the amount of 5% paid to China, the former Corporate Tax Act.