1. The Defendant limited to the Plaintiff:

A. The imposition of corporate tax of KRW 211,007,230 on March 24, 2012 is subject to the disposition of KRW 211,07,230.

1. Details of the disposition;

A. The relationship between the Plaintiff and overseas subsidiaries is established for the purpose of manufacturing and selling new products. The Plaintiff is a corporation established for the purpose of manufacturing and selling new products, under the orders of the U.S. Age (NIKE) to OEM (OE Equi Management). 2) On July 13, 1994, the Plaintiff established TAEWG VIND AIND CO., LTD (hereinafter “TD”) in Vietnam, its subsidiary company, in the order of QING MING MIND (hereinafter “TD”), on October 23, 1995, in the order of China to establish QINGDO TRSCO, LTD (hereinafter “Cheongpy”), and VEMMMMMM COMDDD (hereinafter “BD”) in Vietnam on September 18, 2009.

(3) The Plaintiff owns 100% of the shares of Tae-do and Cheong-do and Cheong-do and the Plaintiff owns 10% of the Plaintiff’s subsidiary company in Vietnam, and Nonparty Tae-do and 90% of the shares. However, in relation to the Plaintiff, an overseas subsidiary is governed by the former Adjustment of International Taxes Act (amended by Act No. 11606, Jan. 1, 2013; hereinafter “International Tax Adjustment Act”).

(4) The Plaintiff provided overseas subsidiaries with various business management and financial support, supply of raw materials necessary for the production of new products, technical support, etc., and exported new products to the Plaintiff. The Plaintiff is running a business by relay trade for exporting new products imported from an overseas subsidiary to the age limit in the United States.

B. 1) On November 1, 2006, the Plaintiff entered into an agreement between the Plaintiff and a foreign subsidiary on the guarantee fee for payment, etc. (i.e., the agreement between the Plaintiff and the Cheongju-doe, and on October 1, 2010, each relay trade agreement including the following content (hereinafter “instant agreement”).

AB concluded the agreement.

The plaintiff shall assume the responsibility under Article 4 (3).