(a) corporate tax of KRW 42,613,90 (including additional taxes);

A. HyundaiMCo Co. and overseas subsidiaries are companies engaged in construction business, etc., and they established CK D Co. and Ltd., a subsidiary company in Cambodia and run a business. The said overseas subsidiary constitutes “foreign related party” under Article 2(1)9 of the former Adjustment of International Taxes Act (amended by Act No. 7956, May 24, 2006) or “foreign related party” under Article 2(1)9 of the former Adjustment of International Taxes Act (amended by Act No. 11126, Dec. 31, 2011) in relation to the Plaintiff.

B. The Plaintiff received payment guarantee fees and payment guarantee fees for the above overseas subsidiaries in the business year 2008, 2009, 2011, 2012, and the Plaintiff received 0.2% of the amount of payment guarantee fees from the above subsidiaries in the business year 2011 and 2012 as payment guarantee fees, and did not receive the payment guarantee fees in the business year 2008 and 2009.

The details are as indicated in the attached Table 1, “the fee rate applicable to MMco” and “the fee to receive” among the “the details of adjustment of income amount for the 2008-2012 Sa business year (excluding the business year 2010). (c) The National Tax Service, around 2012, developed the “the model of determining the arm’s length price for the overseas subsidiaries’ payment guarantee fee” (hereinafter “the National Tax Service model”), and the Defendant calculated the difference between the “payment guarantee fee calculated according to the National Tax Service model” and the “payment guarantee fee calculated according to the National Tax Service model”, on the ground that the “payment fee rate applied by the Plaintiff” does not fall under the “payment guarantee fee rate calculated according to the National Tax Service model” and added the adjusted amount of income to the amount of income for each business year.