1. The corporate tax for the business year 2012, which the Defendant had against the Plaintiff on July 20, 2016, is KRW 1,854,302,552, and corporate tax for the business year 2013.

Details of the disposition

1) The Plaintiff first held more than KRW 100 billion in the annual sales in 2009, and more than KRW 100 billion in the annual sales in the following business year. (2) From around September 2000, the Plaintiff held 39.39% of the issued shares in Sypt Co., Ltd. from August 200, 207, 45% of the issued shares of Sympt Co., Ltd from August 200, and 42% of the issued shares of Kymmpt Co., Ltd from September 209.

1) Meanwhile, the Enforcement Decree of the Restriction of Special Taxation Act applies mutatis mutandis to the requirements for small and medium enterprises under the Enforcement Decree of the Framework Act on Small and Medium Enterprises. As the Enforcement Decree of the Framework Act on Small and Medium Enterprises was amended by Presidential Decree No. 21368 on March 25, 2009, Article 3 subparag. 2 and subparag. 1 of the Framework Act on Small and Medium Enterprises added the requirements for substantial independence of small and medium enterprises from January 1, 201 to the requirements for substantial independence of small and medium enterprises, and Article 3 subparag. 2 and subparag. 3 of the Enforcement Decree of the Restriction of Special Taxation Act provides that companies belonging to related enterprises shall meet the standards for size of small and medium enterprises. 2) After the amendment by Presidential Decree No. 22583 on December 30, 2010 (hereinafter “Enforcement Decree of the Restriction of Special Taxation Act”), Article 2 subparag. 3 of the Enforcement Decree of the Restriction of Special Taxation Act and Article 2 subparag. 2(2) proviso of the Enforcement Decree of the Restriction No. 101 through 21.

On March 31, 2013, the Plaintiff reported corporate tax for the business year 2012, corporate tax for the business year 2013, corporate tax for the business year 31 March 2014, corporate tax for the business year 2015, corporate tax for the business year 31 March 31, 2015, and corporate tax for the business year 2015 on March 31, 2016 to the head of a public tax office, and on the premise that the grace period has expired under the relevant business standards, the Plaintiff is a general enterprise that is not a small or medium enterprise in calculating the tax credit