A. The plaintiff and overseas subsidiaries are companies engaged in the business of manufacturing and selling electronic machinery and appliances, and manufacturing and selling communications machinery and appliances, etc., such as the attached table stating "the calculation details of the defendant's guarantee fee", and these overseas subsidiaries are foreign related parties under Article 2 (1) 9 of the former Adjustment of International Taxes Act (amended by Act No. 6779 of Dec. 18, 2002 and amended by Act No. 9266 of Dec. 26, 2008; hereinafter "international tax law") in relation to the plaintiff.

B. In 2006, the Plaintiff received payment guarantee fees and payment guarantee fees from the above subsidiaries by providing the payment guarantee to the financial institution for the overseas subsidiaries listed in the attached Table, and receiving 0.3% of the amount of payment guarantee fees from the above subsidiaries as the payment guarantee fees.

C. The National Tax Service’s model of determining the arm’s length price for overseas subsidiaries’ payment guarantee fees (hereinafter “the National Tax Service model”) was developed in around 2012, and the Defendant imposed KRW 3,922,06,350 on March 22, 2012, the amount of income calculated by subtracting the “payment guarantee fees received by the Plaintiff” from KRW 19,778,242,828, which is the “payment guarantee fees calculated according to the National Tax Service model,” on the ground that the “payment guarantee fees applied by the Plaintiff” did not fall under the “payment guarantee fees calculated according to the National Tax Service model.”

On the other hand, in relation to the disposition of the above corporate tax, the defendant did not pay the payment guarantee fee according to the National Tax Service model of KRW 19,778,242,830, but the defendant deemed the payment guarantee fee as KRW 12,478,601,279, such as the statement in the "normal payment guarantee fee" column in the attached Table.