(a) 60,754,030 (including additional taxes), corporate tax for the business year 2008;

A. The Plaintiff and overseas subsidiaries are companies engaged in the business of manufacturing, processing, assembling, improving, and selling electronic, electrical, telecommunications, and other machinery, tools, and parts. The Plaintiff and overseas subsidiaries established overseas subsidiaries as shown in attached Table 1. They constitute “foreign related parties” under Article 2(1)9 of the former Adjustment of International Taxes Act (amended by Act No. 7956, May 24, 2006) or “foreign related parties” under Article 2(1)9 of the former Adjustment of International Taxes Act (amended by Act No. 11126, Dec. 31, 2011) in relation to the Plaintiff.

B. From 2008 to 2012, the Plaintiff received payment guarantee and payment guarantee fees from the above overseas subsidiaries, and received payment guarantee fees from the above subsidiaries. The details are as shown in the attached Table 2-1 to 2-5.

C. Tax adjustment and corporate tax assessment 1) The National Tax Service’s “the arm’s length price determination model” (hereinafter “National Tax Service model”) around 2012.

(2) The Defendant developed the amount of income calculated by subtracting the difference of the payment guarantee fee received by the Plaintiff from the “payment guarantee fee rate calculated according to the National Tax Service model” on the ground that the “payment guarantee fee rate applied by the Plaintiff” does not extend to the “payment guarantee fee rate calculated according to the National Tax Service model,” and added the adjusted amount of income to the Plaintiff’s gross income for each business year. (2) On November 7, 2013, the Defendant was amended by Act No. 7956, May 24, 2006; and (3) pursuant to Article 4(1) of the former Adjustment of International Taxes Act (amended by Act No. 11606, Jan. 1, 2013).