1. The Defendant’s penalty tax of KRW 2,304,752,290, which was imposed on the Plaintiff on July 9, 2014, KRW 209,522,935 for the business year 2010.

A. The amount of withholding tax is clear to the extent that the Plaintiff’s guarantee limit exceeds the amount stipulated in the advance refund guarantee agreement.

Therefore, on the premise that the plaintiff would bear the above withholding tax in relation to the Nos. 3 through 6 of Table 1, in the absence of any special agreement for the plaintiff to pay the withholding tax to foreign vessel owners, the part that added the corresponding withholding tax to the tax base of corporate tax to be withheld is unlawful.

The plaintiff's assertion on this part is with merit.

Accordingly, among each of the dispositions in this case, the part of the disposition in this case, which exceeds 5,179,227,874 won (including additional tax 470,838,897 won) in the disposition of imposing the withholding tax of 6,640,035,730 won (including additional tax of 603,665,957 won) for the business year 2010 as to the contract set forth in Nos. 3 through 6 of Table 1 shall be revoked illegally.

The details of reasonable tax calculation shall be 37,192,910,915, 1438, 247, 247, 769, 464, 252, 287, 282, 287, 267, 287, 2650, 267, 378, 267, 378, 267, 3750, 377, 377, 377, 377, 57, 484, 468, 467, 167, 484, 167, 167, 278, 264, 267, 367, 467, 284, 167, 167, 367, 167, 478, 164, 278, 167, 1684

E. According to the theory of lawsuit, the Plaintiff’s assertion exceeds 5,640,035,730 won in the disposition of withholding corporate tax (including additional tax) for the business year 2,304,752,290, which was July 9, 2014 as indicated in the separate sheet Nos. 4 attached to the separate sheet No. 2,304,752,290, which was issued by the Defendant on July 9, 2014 concerning the contracts listed in Nos. 3 through 6 of the separate sheet No. 3 as indicated in the separate sheet No. 3 as indicated in the separate sheet No. 3 as to the contracts listed in the No. 7 or 9 of the table No. 2010, Dec. 9, 2013.