1. The Defendant’s corporate tax withheld at KRW 495,00,000,00 for the business year 2006, which was against the Plaintiff on March 2, 2011.

1. Details of the disposition;

A. A. Investment structure, etc. (1) B (hereinafter “B”) is a limited partnership company established under the German Commercial Act.

B, from May 2003 to October 2009, a total of 29 investments in each Asian country, including Japan, China, India, Singapore, Malaysia, Hong Kong, and Thailand, held 34 German limited companies and 24 local subsidiaries for each investment case, and held 1,980,000,000 as of December 31, 2010, including holding real estate through a established investment holding company, and the final investors are Germany, Luxembourg, Luxembourg, and Austria, as shown in attached Table B’s current status of investors.

(2) C Company (formerly: D Company; hereinafter “C”) is a limited liability company established under the German Limited Liability Company Act on January 5, 2003.

C on February 21, 2003, the Plaintiff established and owned 100% of the shares issued by the Plaintiff.

On the other hand, B raised the purchase price of the Plaintiff’s issued shares to C, and accepted 100% of C’s issued shares on November 10, 2003.

(3) C is identical to B, location, contact point, and director, and has no personnel member.

C sent a business report to B each year, and entered into an investment management contract with E in its own name and received various investment-related advice, such as laws, taxes, and finance, and paid fees.

(4) B obtained approval from the Investment Committee on March 2003, and decided to acquire the Gangnam-gu Seoul Metropolitan Government F building (hereinafter “F building”).

Accordingly, the plaintiff purchased the F building from G Co., Ltd. on April 18, 2003, and completed the registration of ownership transfer on May 16, 2003.

C paid 4,096,710,699 won as incidental expenses to the acquisition of the F building on behalf of the Plaintiff.

(5) B decided to sell the F building with the approval of the Investment Committee around April 2008.

Accordingly, the plaintiff sold F building to H Co., Ltd. on July 1, 2008 and completed the registration of ownership transfer on July 31, 2008.

B. The instant case.