1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff is a company established on January 7, 1997 for the purpose of book publishing business, research and development of teaching materials for young children and import, manufacture, sale, etc., and owned by B 10% of its shares.

C Co., Ltd. (hereinafter referred to as “instant company”) is a company incorporated on February 1, 2002 for the purpose of visiting, educating, etc. using learning papers produced by the Plaintiff, and 61% of the shares of which are owned by B’s father D.

B. From 2006 to 2008, the Plaintiff produced teaching materials, teaching tools, and learning papers for young children and sold them to E Co., Ltd. (2006, 2007) or F Co., Ltd. (2008). The above companies sold teaching materials and teaching implements to G Co., Ltd. in the Seoul metropolitan area, sold learning papers to the instant company, and sold teaching materials, teaching tools, and learning papers to local business operators in the region.

C. The Plaintiff, as a trademark right holder of H’s trademark, had the instant company use the said trademark from 2006 to 2008, but was not paid any price. From 2009, the Plaintiff received from the instant company usage fees equivalent to 6% of the sales amount of educational services.

From 2006 to 2008, the Defendant unfairly reduced the tax burden by the method that the Plaintiff did not receive legitimate trademark right usage fees from the instant company, a person with a special relationship.

In addition to the reasons such as "the reason for taxation of this case", the reason that "the relocation of the plaintiff's factory does not meet the requirements for tax reduction or exemption under Article 63 (1) of the Restriction of Special Taxation Act" and the FF corporation, a related party, reduced the unit price of delivery without justifiable reasons in 2008 and 2009.

It was taxed on the ground that it was "."

Accordingly, applying the provision of the wrongful calculation panel under the Corporate Tax Act to the Plaintiff on March 29, 2012, KRW 593,710,100 of the corporate tax in March 2006, KRW 609,921,450 of the corporate tax in August 1, 2012, and KRW 967,325 of the corporate tax in 2008.