1. On July 4, 2016, the Defendant’s income earner B with respect to the Plaintiff on July 4, 2016, with the amount of income KRW 176,824,068.

1. Details of the disposition;

A. The Plaintiff, a corporation engaged in the business of manufacturing cosmetics, and filed a return on and pay corporate tax for the pertinent business year by appropriating the amount of KRW 176,824,068 (hereinafter “instant interest”) as the accrued income to the representative director B in the business year 2014.

B. In the ordinary audit of the Defendant (from April 14, 2016 to May 3, 2016), the director of the Central Regional Tax Office of China notified the Defendant of the taxation data that “The issues of this case are not actually recovered until the end of the business year 2014, and thus, are deemed to have been flown out of the company.”

C. Accordingly, on July 4, 2016, the Defendant issued a disposition to notify the Plaintiff of the change in income amount (hereinafter “instant disposition”) that recognizes the interest on the instant case as a bonus to the representative director B belonging to the business year 2015, as stated in Article 28(1)4 (b), Articles 52, and 67 of the Corporate Tax Act, and Article 11(9-2 (b), Article 88(1)6, and Article 106 subparag. 1 (b) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 26981, Feb. 12, 2016; hereinafter “former Enforcement Decree of the Corporate Tax Act”).

[Attachment 1] Income amount to be reverted to the business year of income type: bonus from January 1, 2015 to December 31, 2015; KRW 176,824,068 (representative director)

D. On September 28, 2016, the Plaintiff filed a tax appeal with the Tax Tribunal against the instant disposition. However, the Tax Tribunal dismissed it on December 7, 2016.

[Reasons for Recognition] Unsatisfy, Gap evidence 2, 6, Eul evidence 1 and 2, the purport of the whole pleadings

2. The parties' assertion

A. The Plaintiff asserted that: (a) on January 1, 2015, the interest on the instant issue, which was appropriated as the attempted income for the business year 2014 on December 31, 2014, was replaced by the representative director’s provisional payment account; and (b) thereafter, ten (10) times from May 12, 2015 to December 22, 2015.