A. The status of the party is a corporation that concludes a genetic development agreement with the state-owned enterprise, etc. of Indonesia and only distributes profits based on the ratio of shares, and Defendant A tax accounting corporation (hereinafter “Defendant A corporation”) is a tax accounting corporation that conducts business such as acting as an agent for the return, etc., preparation of tax settlement statement and other tax-related documents, and counseling or consultation on taxes with the Plaintiff upon delegation from the Plaintiff, and Defendant A is a tax accountant affiliated with the Defendant corporation, who conducts the Plaintiff’s tax agent business.

B. Upon receipt of the Plaintiff’s delegation as a tax agent for the business year 2008, the Defendant corporation filed a return on the foreign corporate tax amount of KRW 19,96,852,507, which was paid in Indonesia, 9,816,709,389 out of the corporate tax amount of KRW 19,96,852,507, which was deducted from the corporate tax amount for the business year in question (hereinafter “tax credit method”), and the remainder of KRW 10,150,143,118, which was calculated by applying the foreign tax credit to the method of inclusion in deductible expenses (hereinafter “deductible inclusion method”) in calculating the amount of income for each business year in calculating the amount of income for each business year, 15,241,379,215,379,215,374,374,384,3767,2782,767,2787,267,27867,274,767,67,747,67

C. As a result of the consolidated investigation of corporate tax from January 25, 201 to March 28, 201 by the head of the Seoul Regional Tax Office for the Plaintiff from January 25, 2011, to March 28, 2011, foreign tax credit is selected and applied as one of the methods of tax credit and inclusion in deductible expenses, while the Plaintiff is either 2008 and 2009.