1. The Defendant’s disposition on the collection of corporate tax listed in the attached Table 1 as of November 15, 2012 against the Plaintiff, and the collection disposition on January 31, 2013.

1. Details of the disposition;

A. The Plaintiff is a company engaged in the manufacturing business and repair business of various vehicles, and the Plaintiff is a company that is engaged in the research and development service business of diesel engine parts related to a group as an affiliated company of a group by deelms as a French corporation with no domestic place of business.

B. Around April 2008, around December 2009, and around November 2010, the Plaintiff entered into a technology development contract (hereinafter “each of the instant contracts”) under which the Plaintiff would be provided with the human resources management system for a specific diesel engine from DS (hereinafter “instant contracts”) and paid DS in return for the payment of KRW 9,745,81,294 (hereinafter “each of the instant amounts”). From November 2009 to May 201, 2012, the Plaintiff withheld corporate tax by deeming that the amount of usage fees falls under the income and did not fall under the amount of usage fees paid from 4,429,483,676 won (hereinafter “the instant amount”).

C. On November 15, 2012, the Defendant: (a) deemed the instant amount to fall under the royalty income; and (b) rendered a disposition to collect corporate tax of KRW 630,360,800 against the Plaintiff as indicated in the separate sheet No. 1 (hereinafter “instant collection disposition”).

On the other hand, on December 7, 2012, the Plaintiff filed a claim for refund of KRW 402,680,130 of the corporate tax as shown in the separate sheet No. 2, stating that the instant amount does not correspond to the royalty income. However, on January 31, 2013, the Defendant rendered a disposition rejecting the said claim against the Plaintiff on the ground that the instant amount constituted the royalty income (hereinafter “instant refusal disposition”).

On February 7, 2013, the Plaintiff dissatisfied with each of the instant dispositions and filed a petition for an inquiry with the Tax Tribunal, but the said petition was dismissed on April 14, 2014.

[Reasons for Recognition] There is no dispute.