1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Basic facts

A. The Plaintiff is a corporation that operates the manufacturing business of printed circuit board, etc., and the Defendant is a corporation that manufactures and sells semiconductors and related products.

B. From October 2009 to the end of 2012, the Plaintiff transferred (hereinafter “instant transaction”) the printing circuit board for the print circuit board (hereinafter “printed circuit board”) equivalent to KRW 28,331,415,303 in total of the supply value to C (hereinafter “China”), which is the Defendant’s Chinese subsidiary (hereinafter “China”). From October 2009 to the end of 2012, the Plaintiff is as follows.

Tax period (unit of won) 2,375,05, 105, 7,045, 201 2, 2012 2,22,548,491, 2012 2,548,440,830, 282, 2012, 22,548,440,8310, 2012, 22,548,831, 2010, 2010, 2012, 2,548,861,569, 284, 2012

C. The Plaintiff filed a value-added tax return by applying the zero tax rate on the grounds that the instant transaction constitutes an export transaction.

However, after conducting a tax investigation with respect to the Plaintiff, the head of Ansan District Tax Office determined that the instant transaction constituted a domestic transaction between the Plaintiff and the Defendant on November 1, 2014, imposed on the Plaintiff the value-added tax of KRW 295,02,620 (including additional tax of KRW 133,10,152), KRW 1,086,050,470 (including additional tax of KRW 471,64,271), KRW 1,216,738,040 (including additional tax of KRW 506,233,96), KRW 1,168,736,410 for the year 201 (including additional tax of KRW 463,91, value-added tax of KRW 463,965,209, KRW 3019, KRW 209, KRW 2936,9410 for the year 205, KRW 2015 (including additional tax of KRW 46301,294,205).

E. The Plaintiff is dissatisfied with the instant disposition, and the instant transaction was wholly amended by Act No. 11873, Jun. 7, 2013.