1. The legitimate tax amount indicated in the same list among the imposition disposition of each corporate tax stated in the separate sheet No. 1 that the Defendant rendered to the Plaintiff.

1. Details of the disposition;

A. The Plaintiff and the overseas subsidiaries established a number of overseas subsidiaries (hereinafter “instant overseas subsidiaries”) with the aim of designing, installing, and selling various facilities and equipment as follows. The said overseas subsidiaries constitute “foreign related parties” under Article 2(1)9 of the former Adjustment of International Taxes Act (amended by Act No. 11606, Jan. 1, 2013) in relation to the Plaintiff.

1 International Bus business, located in the name of a legal entity, 1 International 2 POSCO E&C Vietm Co., Ltd., Ltd., Ltd., 3 Injury Poet Development Co., Ltd., Ltd., the Corporation, located in the Republic of Korea for 4 HousCO E&C (CHINA) for a long period of 1:5 Santos CMI EPC Equal between China 5 Santos CPC and 6 SOSMIS.A. Ecuador

B. From 2006 to 2012, the Plaintiff received payment guarantee and payment guarantee fees (hereinafter “instant taxable period”) from overseas subsidiaries at the time of receiving a loan from financial institutions, and 0.2% or 0.3% of the amount of payment guarantee from 2009 to 0.3% of the amount of payment guarantee, and reported and paid corporate tax after adding it to gross income.

C. According to the National Tax Service model, the Defendant’s National Tax Service, around 2012, developed “the arm’s length price determination model of overseas subsidiaries’ payment guarantee fees” (hereinafter “the National Tax Service model”). The Defendant calculated the difference between the “payment guarantee fees calculated according to the National Tax Service model” and the “payment guarantee fees calculated according to the National Tax Service model”, on the ground that the “payment guarantee fees applied by the Plaintiff” did not reach the “payment guarantee fees calculated according to the National Tax Service model,” as the adjusted amount of income calculated by subtracting the “payment guarantee fees received by the Plaintiff,” and calculated the adjusted amount of income as the amount of income in the instant taxable period by including the adjusted amount as the gross income in