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 on November 16, 2001 for the purpose of manufacturing aircraft and aircraft-related parts.

B. On January 2, 2004, the Plaintiff moved the Plaintiff’s head office from Songpa-gu B and 2 to Songpa-gu Seoul Building C and D, and on April 1, 2004, moved from Seocho-gu to Seoul E-building 3 floor (hereinafter “E business site”), and on March 15, 2006, moved to Seongbuk-gu Seoul Metropolitan Government F-type Factory Gho (hereinafter “Songnam-si business site”) and transferred on June 4, 2007 to Sacheon-si H (hereinafter “Sacheon-si business site”).

C. The Plaintiff’s transfer of factory facilities to a private place of business after having been equipped with factory facilities for three years at the E and Sungnam workplace, which constitutes “a case where a corporation, which had continued to operate its business for three years or more in the Seoul Metropolitan Area Readjustment Planning Zone, moves its entire factory facilities to an area outside the Seoul Metropolitan Area,” under Article 63-2 of the former Restriction of Special Taxation Act (amended by Act No. 8827, Dec. 31, 2007; hereinafter the same) and was reduced by 50/100 of the corporate tax for the business year from 2008 to 2011, and the entire corporate tax for the business year from the Defendant for 2012 and 2013.

On March 2016, the director of the Busan Regional Tax Office issued a survey on the Plaintiff, and then notified the Defendant of Article 63-2 of the former Restriction of Special Taxation Act that: (a) the Plaintiff could not be deemed to have operated the business with the factory facilities installed in E and Sungnam Business; (b) the type of business (toy) operated in the overconcentration control zone for more than three years, and (c) the type of business (aircraft parts manufacturing business) operated in the overconcentration control zone for more than one year prior to the closure of the business; and (d) the Defendant’s transfer of the factory facilities to another outside of the Seoul Metropolitan area.