A Imprisonment for six months, and Defendant B shall be punished by a fine of twenty thousand won.

However, the defendant A.

Defendant

A is the representative director of Defendant B.

1. Defendant A

A. Around December 2016, the Defendant issued a false tax invoice on Company B with the quarterly value added tax return of 2016, the Defendant entered and issued the tax invoice of KRW 195,600,000 in total four business entities as shown in the attached Table of Crimes, including the issuance of the tax invoice of KRW 134,000,000 as if B supplied goods or services equivalent to the supply price to Limited Company D, although there was no fact that B supplied goods or services equivalent to the supply price of KRW 134,00,000 to Limited Company D.

B. On August 2016, the Defendant received false tax invoice: (a) filed a quarterly preliminary return of value added tax on Company B in February 2016; and (b) did not have received goods or services equivalent to KRW 500 million from “E”; (c) as if Company B received goods or services equivalent to the said amount from “E”, the Defendant was issued a false statement of tax invoice as if Company B received goods or services from “E”.

2. Defendant B, a representative director of the Defendant, committed a violation as described in paragraph (1) in relation to the Defendant’s business.

Summary of Evidence

1. Defendants’ respective legal statements

1. A letter of answer to the F;

1. A report on completion of the survey of value-added taxes and a supplementary survey report;

1. A tax return on value-added taxes by general taxable persons, a list of total tax invoices by customer, and a statement of purchase tax amount not to be deducted;

1. A written confirmation of each transaction details, an electronic tax invoice, a standard contract for private construction works, a written demand for payment, a quotation, and a detailed statement of construction works, a paper invoice and a list of electronic tax invoices;

1. Results of inquiring about the details of transactions of deposits and withdrawal;

1. Partial certificates of registered matters;

1. Application of the Acts and subordinate statutes concerning a written accusation prepared by the head of a heavy tax office;

1. Relevant Article of the Act and the choice of punishment for the crime;

A. Defendant A: Article 10(1)1 of the Punishment of Tax Evaders Act (the issuance of false tax invoices)