1. Each customs duty, value-added tax, which the Defendant issued against the Plaintiff (attached Form 1) Nos. 1, 2, 3, and 6.

1. Details of the disposition;

A. On December 12, 1997, the Plaintiff is a local subsidiary of the Republic of Korea established by Sweden B (hereinafter “main company”) that was a Sweden-based corporation on December 12, 1997 and sells C motor vehicles and related parts to D Drlers in the Republic of Korea.

B. A goods supply contract and a transfer price adjustment 1) The Plaintiff entered into a goods supply contract with the head office on January 1, 2008 (hereinafter “instant goods supply contract”).

(B) The Plaintiff entered into an import declaration number: D and 8,937 motor vehicles and related parts imported by the Plaintiff from the head office from September 1, 2010 to August 20, 2014; and “the instant imported goods”

(2) According to the instant contract for the supply of goods, the price of goods imported by the Plaintiff from the head office is determined as “transfer price” as determined by the computation method of the arm’s length price under the net trade profit ratio Act. The Plaintiff, after the end of each fiscal year, compared the actual operating income and the objective operating income equivalent to the arm’s length price achieved by the Plaintiff, transfers the amount in excess to the head office (hereinafter “the amount in excess”) in cases where the actual operating income exceeds the target operating income, and instead, in cases where the actual operating income falls short of the target operating income, he/she receives the amount in excess of the target operating income from the head office (hereinafter “the amount in excess of the ex post facto payment”).

3) The Plaintiff remitted the amount of the transfer price adjustment to the head office to the head office in the 2009 to 2014 fiscal year (excluding 2012 fiscal year) (hereinafter “the transfer price adjustment amount that the Plaintiff remitted to the head office in the 2010 to 2014 fiscal year from which the instant imported goods were imported” refers to “the amount of the transfer price adjustment amount that

(C) The Plaintiff filed an import declaration of the customs value of imported goods at the transfer price in 2009 and 2010, and the ex post facto payment to the head of the Suwon Customs Office on March 31, 201 and July 12, 201.