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 corporation established by the pilot affiliated with C, an incorporated association, with 100% investment of 10% by pilots affiliated with C, and is engaged in the collection of pilotage fees on behalf of the pilot affiliated with C.

A pilot belonging to C holds the plaintiff's shares at the share rate of 3.2% to 4.0%.

D A Co., Ltd. (hereinafter referred to as “D”) is running a pilotage service, which transports pilots belonging to C and receives pilotage fees from the ship owners to the ship requesting pilotage with its own pilot ships.

B. From 2013 to 2016, the Plaintiff paid a pilot, who is an investor, allowances such as salaries, food expenses and expenses on duty, and merchandise coupons, and paid the 4th insurance premium to the pilot, and then reported and paid corporate tax by including it in deductible expenses.

C. As a result of conducting a tax investigation with the Plaintiff from July 12, 2017 to September 22, 2017, the Commissioner of the Busan Regional Tax Office: (a) deemed that the Plaintiff had not provided labor between 2013 and 2016 until the business year 2016, the Plaintiff’s payment of wages of KRW 2.749 billion, allowances of KRW 32 million, and four premium of KRW 168 million borne by the Plaintiff in the payment of the said salary (hereinafter “instant personnel expenses”), and gift certificates of KRW 241,890,000, as follows, shall be deemed as having paid KRW 122,316,050 (the processed expenses without evidentiary evidence to the business year from 2012 to 2016), and notified the Defendant as taxation data.

Accordingly, on November 1, 2017, the Defendant imposed corporate tax (including additional tax) specified in the list of the disposition imposing corporate tax (hereinafter “instant disposition”) on the Plaintiff on the following grounds: (a) the instant personnel expenses, gift certificates, processing expenses, total amount of KRW 3,583,206,050.

E. The Plaintiff is dissatisfied with the instant disposition, and on January 29, 2018, to the Tax Tribunal.