1. The Defendant’s value-added tax of KRW 3,241,687,90 against the Plaintiff on July 10, 2012 and KRW 2,004 against the Plaintiff on July 10, 200.

1. Details of the disposition;

A. The Plaintiff is a company established on March 9, 1995 for wholesale and retail business, manufacturing business of precious metal, export and import business, etc.

B. From January 1, 2004 to June 30, 2004, the Defendant purchased gold bullion (hereinafter “instant gold bullion transaction”), and paid the price of gold bullion (hereinafter “gold bullion transaction”) in total from 32,416,879,000 won in total, from the purchase price of the gold bullion (hereinafter “instant purchaser”) to 32,416,879,000 won in total, from the purchase price of the instant purchase price, and paid the price after deducting the purchase price of each of the instant purchase price from the purchase price of the instant gold bullion to 632,381,00 won in total, from July 1, 2004 to December 31, 2004 (hereinafter “the instant purchase price”). The Defendant received the purchase price of each of the instant purchase price from the purchaser and filed a return of value-added tax for the pertinent taxable year by deducting it from the input price.

C. The Defendant, while having knowledge that the Plaintiff had gone through a modified transaction process from the first import to the final export by using the fact that the zero-rate tax rate was applied to the export of gold bullion under the Value-Added Tax Act, received unjustly deduction or refund of the input tax amount related to gold bullion export. The Defendant determined that the ten-year exclusion period was applied to the case where the input tax amount was deducted or refunded by fraudulent or other unlawful means, and that the ten-year exclusion period was applied to the Plaintiff on July 10, 2012 (i.e., the Plaintiff’s additional tax amounting to KRW 3,241,687,90 and additional tax amounting to KRW 3,151,244,790 (i.e., the additional tax amounting to KRW 2,827,076,000 for the additional tax amounting to KRW 324,827,076,632,690 for the previous import to the final export).

The imposition of the above additional tax shall be excluded.