A. The Plaintiff is a domestic corporation (hereinafter referred to as “B”) in which Switzerland’s related company B (hereinafter referred to as “B”) holds 100% equity shares as its main business to manufacture and sell tobacco as a domestic corporation (hereinafter referred to as “B group”).

B. From July 29, 2015 to November 28, 2015, the Seoul regional tax office conducted an integrated investigation of corporate tax for the business year 2014 from the Plaintiff’s 2010 to the Plaintiff’s 2014. ① With respect to the Plaintiff’s inclusion of the total amount of 12,168,249,040 won (including basic wages, bonuses, etc.; hereinafter “instant remuneration”) paid to executives including the representative director from 2010 to the deductible expenses as personnel expenses, the Seoul regional tax office included the total amount of 5,168,249,040 won paid in excess of 1.4 billion won per annum approved at the Plaintiff’s general meeting of shareholders from 2010 to 2014 in the relevant sales list of the vehicles (hereinafter “instant vehicles”), deeming that the Plaintiff’s relative sales price of the vehicles and the incentive for value-added tax for 984,286,175 won (hereinafter “the pertinent sales list”) within 2010.

C. Accordingly, the defendant shall attach the attached Table [Attachment] to the plaintiff on each date stated in the "Disposition Date."