A. On February 1, 1984, the Plaintiff is a non-profit domestic corporation established under the Military Personnel Mutual Aid Association Act (hereinafter “non-profit corporation”) to promote the stabilization of livelihood and welfare of military personnel and civilian employees.

B. The Plaintiff: (a) KRW 288,810,205,058 (i.e., the amount paid according to the retirement benefit payment rate proportional to the payment period plus the principal in the event the Plaintiff loses membership due to discharge of his/her member, etc.; (b) the amount paid by the Plaintiff based on the annual income statement for the business year 201 (i.e., the amount paid by calculating the ratio of the principal when the subscription period for the membership deposit account holder for the membership deposit with the Plaintiff’s deposit deposit expires or the contract for the donation expires; and (c) the amount paid by calculating the ratio of the principal in addition to the principal in the event the net income accrues as a result of the operation of the special additional dues for the business year 2011; and (d) the amount determined and paid by the Operating Committee in the event the net income accrues as a result of the operation of the special additional dues for the business year 64,910,65,003 won.

C. On March 25, 2015, the Plaintiff filed a request for correction with the Defendant to the effect that the portion reported in excess of the limit of the reserve fund for essential business purposes in deductible expenses is recognized as deductible expenses and that the amount reported in excess of the limit of the reserve fund for essential business purposes in deductible expenses shall be refunded KRW 5,819,136,805 in the business year 201, on the grounds that the said retirement benefit surcharge and the membership consignment surcharge constitute deductible expenses (interest expenses).

On May 18, 2015, the Defendant rejected the Plaintiff’s request for correction, and the Plaintiff appealed and filed an appeal with the Tax Tribunal on August 6, 2015, but was dismissed on March 23, 2016.

E. Meanwhile, on October 29, 2015, the Defendant ex officio KRW 1,330,068,436 of the Plaintiff’s corporate tax for the business year 2011 due to other issues.