A. The Plaintiff applying the grace period for small and medium enterprises is a corporation that runs the business year from January 1 to December 31 of each year, and its equity capital exceeds KRW 100 million for the first time in the business year 2009, and Article 5(1) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 21307, Feb. 4, 2009) (amended by Presidential Decree No. 22037, Feb. 18, 2010; Presidential Decree No. 21307, Feb. 4, 2009; Presidential Decree No. 21307, Feb. 4, 2009); Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 22037, Feb. 18, 2010); Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 21301, Feb. 21, 2010).

B. Article 3 subparag. 2 of the Enforcement Decree of the Framework Act on Small and Medium Enterprises (amended by Presidential Decree No. 21368, Mar. 25, 2009) amended by Presidential Decree No. 21368, the Enforcement Decree of the Framework Act on Small and Medium Enterprises (amended by Presidential Decree No. 21368, Mar. 25, 2009), with respect to “related company” as to “related company,” the number of full-time workers calculated pursuant to Article 7-2, referring to subparagraph 3 of Article 2 of the Enforcement Decree of the Framework Act on Small

(ii) Article 2(1)(c) of the Enforcement Decree of the Restriction of Special Taxation Act was amended by Presidential Decree No. 22583 on December 30, 2010, and Article 2(1)(3) of the Enforcement Decree of the Restriction of Special Taxation Act provides that an enterprise shall not be an enterprise that exceeds the criteria set forth in subparagraph 1 of Article 3, and Article 1(1)(c) of the Addenda shall enter into force on January 1, 201.