1. The Defendant imposed KRW 149,145,362 upon the Plaintiff on December 2, 2013, KRW 558,064,20 in the imposition of KRW 149,145,362.

(c)bed;

hereinafter the same shall apply.

Article 17(1) of the Act provides that a national having a special relationship with respect to the retained earnings of a foreign corporation with its head office or principal office in a state or region where the tax burden of the corporation is 15 percent or less of actually accrued income is deemed to have been distributed. F is a foreign corporation located in Hong Kong. The corporate tax rate of Hong Kong is 16.5% and is not a State subject to the above provision. Although F did not pay corporate tax in Hong Kong, it is not subject to the above legal entity's corporate tax reduction or exemption but did not file a tax return. (2) The Plaintiff concluded a bareboat charter contract with the related parties, such as the Plaintiff's in-house director B, etc. from 2010 to 2012; (3) during the period of 60% of the insurance premium paid by the Plaintiff; (4) 97% of the total amount of charterage paid by the Plaintiff's in-house director B, etc. 97% of the total amount of charterage paid to the specially related parties, 97% of the total amount paid by the Plaintiff 97.

[Ground of recognition] Facts without dispute, each of the evidence mentioned above, Gap evidence No. 3, Eul evidence No. 4, the whole purport of the pleading, and the denial of wrongful calculation under Article 52 (1) of the Corporate Tax Act, is a corporation.