(a) impose the corporate tax of KRW 5,386,869,350 on the business year of 2008;

A. The Plaintiff and the overseas subsidiaries are companies that run various business, such as sales business of goods. The Plaintiff and the overseas subsidiaries established a foreign subsidiary as shown in attached Table 1 and run a business. These overseas subsidiaries constitute “foreign related parties” as prescribed by Article 2(1)9 of the former Adjustment of International Taxes Act (amended by Act No. 7956, May 24, 2006) and Article 2(1)9 of the former Adjustment of International Taxes Act (amended by Act No. 11126, Dec. 31, 201) in relation to the Plaintiff.

B. From 2008 to 2012, the Plaintiff received payment guarantee fees and payment guarantee fees from the above overseas subsidiaries to the financial institution, and received 0.3% to 0.5% of the amount of payment guarantee fees from the above subsidiaries as payment guarantee fees. The details are as indicated in the column of “payment guarantee fees” in the attached Table 2.

C. Tax adjustment and corporate tax assessment 1) The National Tax Service’s “the arm’s length price determination model” (hereinafter “National Tax Service model”) around 2012.

A) The Defendant developed the fee rate, which the Plaintiff applied, does not extend to the “payment guarantee fee rate calculated according to the National Tax Service model,” and calculated the difference between the “payment guarantee fee fee received by the Plaintiff” and the “payment guarantee fee calculated according to the National Tax Service model,” as the adjusted amount of income, and added the adjusted amount of income to the gross income for each business year. The details are as indicated in the respective “payment rate” and “amount of income” in the attached Table 2. 2) The Defendant was amended by Act No. 7956, May 24, 2006 and enacted by Act No. 11606, Jan. 1, 2013.