2. The costs of the lawsuit are assessed against the defendant.

On November 22, 2011, the Plaintiff, a corporation established on March 14, 200 and engaged in the business of producing Internet communications services and multi-media content and the business of unfolding the Internet, concluded a license agreement on the distribution right (hereinafter “instant license agreement”) with Hungary-based corporation (hereinafter “B”) to provide exclusively to domestic customers through the Plaintiff’s order-based video service (VOD), and did not withhold corporate tax pursuant to Article 12(1) of the Convention between the Government of the Republic of Korea and the Government of Hungary for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (hereinafter “Korea-Hungary Tax Treaty”) from 2012 to 2013.

As a result of investigating the appropriateness of the tax exemption under the tax treaty against the plaintiff, the director of the Seoul Regional Tax Office: (a) deemed that B is merely a conduit company that performs only the role of the formal transaction party; and (b) deemed that the actual beneficial owner was D (hereinafter referred to as D) the parent company B, and notified the defendant of the tax data that the plaintiff collects corporate tax (one thousand Won) pursuant to Article 12(2) of the Convention between the Government of the Republic of Korea and the Prevention of Double Taxation and the Prevention of Fiscal Evasion with respect to the Taxes on Income paid by the plaintiff without withholding from B (hereinafter referred to as the "Korea-Nd World Tax Treaty").

Accordingly, on August 7, 2017, the Defendant applied the withholding tax rate (15%) under the Korea-Nd World Tax Treaty pursuant to Article 2-2 of the Adjustment of International Taxes Act to the Plaintiff on August 7, 2017, and notified the Plaintiff of KRW 58,228,760 for the corporate tax (including additional tax), which reverts to the Plaintiff (including additional tax), KRW 99,206,940 for the corporate tax (including additional tax) belonging to the Plaintiff for the year 2013, and KRW 7,877,910 for the Plaintiff on October 1, 2018, respectively.

hereinafter referred to as "the case."