A. From September 14, 2017 to September 29, 2017, the National Tax Service audited the Seoul Regional Tax Office. As a result, the Plaintiff pointed out that: (a) the interim dividend of KRW 249,694,260, and 640 was paid to B at the time of interim dividend in the business year 2014; and (b) no additional tax was imposed on the Plaintiff without submitting the payment record.

B. Accordingly, on March 22, 2018, the head of the Guro Tax Office imposed penalty tax on the Plaintiff pursuant to Article 76(7) of the former Corporate Tax Act (amended by Act No. 12850, Dec. 20, 2016; hereinafter the same) on the Plaintiff, subject to Article 49(1)2 of the former Framework Act on National Taxes (amended by Act No. 14382, Dec. 20, 2016; hereinafter the same), imposed corporate tax for the year 2014 (additional tax on the amount of additional tax).

C. Local tax authorities, including the Defendants, imposed corporate local income tax on the Plaintiff at KRW 249,649,260,640, which is the amount of non-submission of the above payment statement, on KRW 249,640,640, which is the amount of 200,00,000 (hereinafter “instant Local Tax Act”) by applying the tax rate prescribed in Article 103-30(5) of the former Local Tax Act (amended by Act No. 13427, Jul. 24, 2015; hereinafter “instant Local Tax Act”), and imposed corporate local income tax (additional tax to be submitted) at KRW 49,298,520, which is the amount of additional tax (additional tax to be paid) to the Plaintiff, and then imposed corporate local income tax for KRW 2014,00,000 for each of the competent local governments under Article 88 of the former Enforcement Decree of the Local Tax Act (amended by Presidential Decree No. 26431, Jul. 24, 2015, 2018, 2018).

(hereinafter “each disposition of this case”). D.