1. On December 4, 2013, the Defendant stated the “additional Tax” column in the list of separate taxation dispositions that the Plaintiff rendered.

1. Details of the disposition;

A. On February 12, 2010, the Plaintiff was a juristic person engaged in an engineering work, and jointly with the housing site development business company, the Plaintiff was selected as the contractor of the national rental housing complex construction work (hereinafter “instant project zone”), which is a project implementer of the housing site development project (hereinafter “SA”) and entered into a contract for construction work with the EAP and the construction cost of KRW 13,182,186,830.

The instant construction was composed of “stopway construction works among soil, road, packing, excellent water, sewage, water supply, structure construction, incidental construction, and error road construction.”

B. E. E.S. project implemented the construction project of national rental housing in addition to the above housing site development project in the project district of this case. Among the project district of this case, E.S. 2 complex was contracted out by Scco Construction Co., Ltd., in the project district of this case, the king Two District Complex was contracted out for construction work of national rental housing.

C. The director of the Seoul Regional Tax Office, from January 2013 to May 2013, conducted a regular tax investigation with respect to EP from May 2013, notified the Defendant of the taxation data that the instant construction services supplied to EP on May 27, 2013 cannot be deemed as construction services incidental to national housing construction services, and thus, is not subject to value-added tax exemption.

Accordingly, on December 4, 2013, the Defendant issued a disposition imposing KRW 620,862,870 in aggregate of the value-added tax and additional tax of KRW 620,837,650 in 201 (hereinafter “instant disposition”) for the second period of 2010, as shown in the list of the imposition disposition attached thereto, to the Plaintiff on December 4, 2013 (hereinafter “instant disposition”).

E. The Plaintiff is dissatisfied with the instant disposition and on January 2014.