1. The Defendant’s rejection of correction of KRW 115,539,249 of corporate tax against the Plaintiff on January 6, 2017 shall be revoked.

2...

1. Details of the disposition;

A. The Plaintiff is a corporation that runs a business of treating livestock excreta, treating sewage and wastewater, and performing high concentration members of the Daejeon Pungdong-gu, Daejeon Pungdong-gu, which is a company that performs a business of treating livestock excreta, treating sewage and wastewater, or performing a business of treating high concentration members (the Plaintiff is a company that serves as a pen in a liquid or solid manner that can separate mixtures by passing through a specific component of the liquid, liquid, or gaseous, and is used for the purification of contaminated water, purifying polluted water, and dializing seawater

B. Around January 2008, the Plaintiff established a local corporation (mutual name: D (Gu E; hereinafter “instant local corporation”) which is an object business of environmental facility-related business in California, California (U.S.).

At the time of the establishment of the instant subsidiary, the Plaintiff owned 100% of the shares of the said legal entity. Since 2011, the Plaintiff’s shares were reduced to 53.85%, and F, the largest shareholder of the Plaintiff, 41%, and executives and employees of the instant subsidiary, etc. hold the remainder of shares.

C. From 2011 to 2015, the Plaintiff lent KRW 6,847,595,503 to the instant local subsidiary with facilities and operating funds.

(hereinafter “instant loan”). From 2011 to 2015, the Plaintiff considered the instant loan as a provisional payment unrelated to business, and did not include the interest paid (including KRW 94,673,180 in year 201, KRW 94,673,180 in year 201, KRW 94,673,180 in year 201, KRW 119,240,460 in year 2013, KRW 129,696,550 in year 2014, KRW 158,935,50 in total, KRW 570 in total, and KRW 570,864,330 in total as losses.

On October 20, 2016, the Plaintiff filed a request for corporate tax reduction or exemption on the ground that the instant loans are directly related to the Plaintiff’s business activities and do not constitute a provisional payment unrelated to the Plaintiff’s business activities, and that the non-deductible interest was revoked. On January 10, 2017, the Defendant rejected the correction on the ground that the instant loans were not related to the Plaintiff’s business.

(hereinafter referred to as “instant refusal disposition”). Grounds for recognition: Items A through 3, 20, and 20.