A. The status of the parties and Bboard import (1) The Plaintiff is composed of a number of beams with equipment to examine whether semiconductors are good or inferior at the final stage of the production process of semiconductor testing equipment.

C. A company, the main business of which is the establishment, repair, etc. of the headquarters of semiconductor testing equipment in Japan, is the domestic branch of C. D. D. A company (hereinafter referred to as “D”) is a Singapore corporation with the global logistics center (hereinafter “ILC”) of E group (C. its head office) having a branch office in each foreign country. C and D hold 37.48% and 62.52% and 100% in total, respectively.

(2) The Plaintiff, which is a component of semiconductor inspection equipment that is a component of semiconductor inspection equipment sold by C to a domestic semiconductor manufacturer, is a package for exchange repair provided when a malfunction occurs.

In the event of failure, the cause of the failure is examined and the engineering service is provided to replace it with a product operating normally.

(3) The Plaintiff, while importing a new product B, which has no capacity to repair from D that controls and manages B, is a new product B, which has no capacity to repair from D, and then has reported the import price to D by 1/5 of purchase cost, etc., while importing a renewable B, each of which is operated normally (hereinafter “new product B,” and “reviced B,” respectively. This is the value obtained by dividing the purchase cost by 5 by five, by deeming that the Plaintiff’s service life of B, was at will for five years, and only one time per year.

(4) The ownership of B, even after the Plaintiff’s importation, is reserved against D (the Plaintiff is entrusted with custody). When the Plaintiff replaces a new product or a renewable product through engineering services, the ownership is transferred to the customer company, and the Plaintiff is part of the service cost received from the customer company to B.