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 was established on August 28, 1990 and operated the manufacture and sale of leather products, and rubber products manufacture and sale business.

B. On December 24, 2015, the Plaintiff paid KRW 2,873,456,287 to the representative director B and the auditor C in total as an interim retirement allowance following the conversion of the annual salary system.

C. From November 23, 2016 to January 3, 2017, the Defendant conducted a corporate tax integration investigation for the Plaintiff’s business year 2015, and conducted an interim settlement of KRW 2,586,82 among the retirement allowances paid to B and C on the ground that the said retirement allowances do not constitute retirement allowances paid on the actual ground of retirement. The Defendant denied interim settlement of KRW 2,586,82 among the retirement allowances paid to B and C on the ground that the said allowances do not constitute retirement allowances paid on the ground of retirement. ② The non-deductible portion of the Belgium fee paid upon the export of the goods shall be deemed as entertainment expenses, and ③ the non-deductible portion of the Belgium fee paid upon the export of the goods shall be deemed as entertainment expenses, and the disposition of imposition of KRW 797,185,302

① On April 28, 2017, the Plaintiff filed an administrative appeal with the Tax Tribunal. On December 19, 2017, the Tax Tribunal dismissed the Plaintiff’s claim (i) for the remainder of KRW 722,484,263 (==797,185,302 – KRW 74,701,039) of the instant disposition by including the amount of the labelling labeling fee in deductible expenses and reducing the amount of KRW 74,701,039 from among the instant disposition.

E. The Plaintiff’s lawsuit in the instant case pertains only to KRW 617,386,882 of the relevant tax amount, which was performed by excluding the interim settlement of the retirement pay in deductible expenses among the instant disposition.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1-3, Eul evidence No. 1 (including branch numbers; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion B and C, on June 28, 2015, intended to convert the benefits into the annual salary system and not receive a retirement allowance in the future. Accordingly, the Plaintiff completed the interim settlement of the retirement allowance by paying KRW 2,873,456,287 to B and C in accordance with the retirement allowance payment rules for officers.