A. On March 20, 2012, corporate tax of KRW 1,728,245,60 imposed on the Plaintiff for the business year 2006.

A. The plaintiff and overseas subsidiaries are companies engaged in the business of textile, industrial materials, chemistry, heavy industry, construction, trade, etc. The plaintiff and overseas subsidiaries established overseas subsidiaries as shown in the attached Table 1. They are foreign related parties as defined in 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 Trade Act").

B. The Plaintiff received payment guarantee fees and payment guarantee fees in the attached Table 1 for overseas subsidiaries from Nos. 1 to 11 of the attached Table 2006, and received 0.3% of the amount of payment guarantee fees from the above subsidiaries as payment guarantee fees. The details are as shown in the attached Table 2-1, the terms of “the Plaintiff’s fee rate” and “payment guarantee fees” as stated in the attached Table 2-1. 2) The Plaintiff provided payment guarantee to financial institutions for overseas subsidiaries from Nos. 1 to 17 of the attached Table 207, and received 0.3% of the amount of payment guarantee fees from the above subsidiaries as payment guarantee fees. The details are as shown in the attached Table 2-2, the column of “Plaintiff’s fee rate” and “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 calculated the difference between the “payment guarantee fees calculated according to the National Tax Service model” and the “payment guarantee fees calculated according to the National Tax Service model” and the “payment guarantee fees calculated according to the National Tax Service model” and the “payment guarantee fees received by the Plaintiff” from the “payment guarantee fees calculated according to the National Tax Service model,” and calculated the adjusted amount of income as the adjusted amount.