A. The Loshes Group (hereinafter referred to as the “Lishes Group”) is a multi-national company whose mother company is the Roshes Corporation, the Netherlands Corporation, and the British Corporation, and whose main business is the exploration and extraction of crude oil, the production of refined petroleum products and chemical products, the production of natural gas, and the production of electric power.

The Plaintiff, as an affiliated company of the People’s Group, produces and sells basic petroleum products, chemical products, etc., has its head office in Hong Kong (hereinafter “Plaintiff’s head office”) and has a branch office in Korea (hereinafter “Plaintiff’s branch”).

B. From January 1, 1999 to December 31, 2003, the Plaintiff’s head office included the total amount of KRW 393,680,399 in the Plaintiff’s head office for the business year of 1999; KRW 563,590,023; KRW 193,78,982 in the business year of 2001; KRW 20,847,355 in the business year of 2002; KRW 14,418,819 in the total amount of KRW 1,186,315,578 in the business year of 209; KRW 293,97 in the Plaintiff’s head office for the business year of 205; KRW 390 in the Plaintiff’s head office for the business year of 209; KRW 2093,578 in the Plaintiff’s interest income; KRW 390 in the business year of 200578,1940 in the business year of 209.

C. From December 9, 2004 to January 26, 2005, the director of the Seoul Regional Tax Office conducted a corporate tax investigation on the Plaintiff’s corporate tax for the business year from 1999 to 2003. Since the Plaintiff’s headquarters is a nominal company on the document, the Plaintiff’s branch’s interest income from the instant headquarters is considered as the Plaintiff’s domestic source profit and loss.