A. As a result of the audit conducted by the Seoul Regional Tax Office from September 14, 2017 to September 29, 2017, the National Tax Service pointed out that the Plaintiff did not impose additional tax on the Plaintiff on the interim dividend of KRW 249,694,260,640 on Company B in 2014 and did not submit the payment record.

B. Accordingly, on March 22, 2018, the head of the Guro Tax Office imposed penalty tax on the Plaintiff pursuant to Article 76(7) of the former Corporate Tax Act (amended by Act No. 12850, Dec. 20, 2016; hereinafter the same) on the Plaintiff, subject to Article 49(1)2 of the former Framework Act on National Taxes (amended by Act No. 14382, Dec. 20, 2016; hereinafter the same), imposed corporate tax for the year 2014 (additional tax on the amount of additional tax).

C. Local tax authorities, including the Defendants, imposed corporate local income tax on the Plaintiff in KRW 249,649,260,640, which is the amount of non-Submission of the payment record, on KRW 249,640,640, which is the amount of 200,00,000, on the basis of the tax rate prescribed in Article 103-30(5) of the former Local Tax Act (amended by Act No. 13427, Jul. 24, 2015; hereinafter “instant Local Tax Act”), and imposed corporate local income tax (additional tax) on KRW 49,298,520, which is the amount of additional tax (additional tax to be submitted) on the Plaintiff, based on the pro rata distribution ratio for each competent local government under Article 88 of the former Enforcement Decree of the Local Tax Act (amended by Presidential Decree No. 26431, Jul. 24, 2015; hereinafter “the head of the Jung-gu Incheon Metropolitan City (hereinafter “Defendant”) applied the pro rata 2136,5138.

(hereinafter “each disposition of this case”) D.

As to this, the Plaintiff on 2018.