1. Of the judgment of the court of first instance, the part against the Plaintiff, which orders revocation below, shall be revoked.

1. Details of the disposition;

A. On November 16, 2001, the Plaintiff was a juristic person established for the purpose of engaging in the business of manufacturing aircraft and aircraft-related parts, etc., and transferred its head office as follows:

On October 24, 2002, the head office of Songpa-gu Seoul Ma building at the time of the establishment of the head office of the Songpa-gu Seoul Ma building at the seat of 1 Seoul Ma building at the seat of its head office on the date of the relocation of the sequence 2, Songpa-gu Seoul Ma building B and 2 on January 2, 2004, the 3rd or lower floor of the Seocho-gu Seoul Ma building on March 31, 2004.

5 On March 15, 2006, Seongbuk-gu Seoul Special Metropolitan City F factory G heading (hereinafter referred to as "Songnam-gu Business").

6. On June 4, 2007, Sacheon-si H (hereinafter referred to as "Sacheon-si Place of Business")

B. The Plaintiff is recognized as falling under the case where a corporation that has continued to operate a business with factory facilities for three or more years in an overconcentration control region in the Seoul Metropolitan area moves its entire factory facilities to an area outside the Seoul Metropolitan area and starts its business by relocating the factory facilities to a private workplace in E and Sungnam workplaces, and was reduced by 50/100 of the corporate tax for the business year belonging to the Defendant.

C. On March 2016, the director of the Busan Regional Tax Office issued an investigation on the Plaintiff, and then notified the Defendant of the exclusion from the application of the corporate tax reduction and exemption provisions under Article 63-2 of the former Restriction of Special Taxation Act, on the following grounds: (a) the Plaintiff cannot be deemed to have operated the business with factory facilities at E and Sungnam Business; and (b) even if the Plaintiff equipped with factory facilities, the type of business (toy manufacturing business) operated for at least three years in the overconcentration control region in the Seoul Metropolitan Area was discontinued; and (c) the type of business (aircraft parts manufacturing business)

On March 16, 2016, and May 3, 2016, the Defendant indicated the Plaintiff as follows: