1. The Defendant:

A. On March 20, 2012, imposition of corporate tax of KRW 65,155,510 on the Plaintiff for the business year of 2007; and

1. Details of the disposition;

A. Nitene ethyl Co., Ltd. mainly produces and sells cooling pressure and liver steel, grheium, galium, and gyllite steel plates as indicated in the following table. The overseas subsidiaries established overseas subsidiaries and run business as indicated in the following table. They constitute “foreign related parties” under Article 2(1)9 of the former Adjustment of International Taxes Act (Amended by Act No. 6779, Dec. 18, 2002; Act No. 11126, Dec. 31, 201) or “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.

B. In the business year of 2006, Liquefied Co., Ltd. received payment guarantee fees and payment guarantee fees from financial institutions for the above overseas subsidiaries, and received 0.8% of the amount of payment guarantee fees from the above subsidiaries as payment guarantee fees. The details are as shown in the attached Table 1, “amount of payment guarantee”, “amount of payment guarantee”, “amount of fees applied by the Plaintiff”, and “amount of fees paid”, “amount of fees to be paid”, from 2008 to 2012. 2) Liquefied Co., Ltd. paid payment guarantee to financial institutions for the above overseas subsidiaries from 2008 to 2012, and received 0.8% of the amount of payment guarantee fees from the above subsidiaries. The attached Table 2 is as follows.

C. The National Tax Service’s development of “the arm’s length price determination model” in around 2012 (hereinafter “National Tax Service model”) and the Defendant’s “the fee rate applied by UNNTA” does not extend to the “payment guarantee fee rate calculated according to the National Tax Service model.”