2. The costs of lawsuit shall be borne by the Plaintiff.

A. On July 14, 200, the Plaintiff, a foreign-capital invested company established by Rednaul Group BV, the Netherlands, investing 70.1% of the equity shares, was granted tax reduction or exemption on the ground that the electronic control engine (hereinafter “instant engine”) constituted a business involving high technology by the Minister of Finance and Economy on December 19, 2003.

B. From 2003 to 2003, the Plaintiff reported the income generated from the instant engine based on the agency sales price of the engine for maintenance and was exempted from corporate tax.

C. The director of the Seoul Regional Tax Office, from August 13, 2012 to January 16, 2013, conducted an integrated investigation of corporate tax for the business year 2007-201 with respect to the Plaintiff (hereinafter “instant tax investigation”), and on February 4, 2013, the director of the Seoul Regional Tax Office revoked the abated or exempted corporate tax for the business year 2008-2010 on the basis of the export price of the instant engine’s market price, rather than the agency sale price for engines for maintaining the market price, and notified the foreign related party of the result of the tax investigation that the additional tax should be imposed.

On March 6, 2013, the Plaintiff filed a request for pre-assessment review. On May 27, 2013, the Commissioner of the National Tax Service decided on the following purport: (a) it is difficult to view both the agency sales price of an engine for maintenance purposes or the OEM export price to the foreign related party as the market price of the instant engine; (b) however, (c) it is likely to impose tax after calculating the amount calculated by multiplying the amount calculated by multiplying the relevant ratio of the reduced or exempted parts among the parts input to the final product sales by the market price (hereinafter “original law”).

E. In accordance with the purport of the aforementioned pre-assessment review determination, the Defendant recalculated the reduced or exempted income and the reduced or exempted income under the cost-based method and notified the corporate tax for the business year 2008-2010 as indicated in the attached Table 1 on June 21, 2013.

(hereinafter referred to as the "instant disposition") impose a tax on the remaining tax amount, excluding the amount revoked by the Tax Tribunal.