1. The Defendant’s imposition of global income tax of KRW 1,724,745,180 against the Plaintiff on August 1, 2013 shall be revoked.

2.

1. Details of the disposition;

A. In order to recover the money loaned by the Plaintiff to B (total KRW 2 billion), the Defendant acquired shares of Cambodia as a local corporation C (hereinafter referred to as “C”) from B, and upon de facto liquidation on March 30, 2008, the Defendant deemed KRW 3,193,156,00 in excess of the amount used by the Plaintiff for acquiring the said shares among the money acquired by the Plaintiff through the distribution of remaining assets as dividend income under Article 17(1) of the Income Tax Act and notified the Plaintiff of the global income tax of KRW 1,724,745,180 in August 1, 2013.

(hereinafter referred to as “instant disposition”). (b)

The Plaintiff filed an appeal with the Tax Tribunal on October 15, 2013, but was dismissed on April 11, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1, the purport of the whole pleadings

2. To make entries in the attached statutes concerned;

3. Whether the instant disposition is lawful

A. 1) The Plaintiff is the Plaintiff’s land of 145 Punishment (hereinafter “instant land”) located in Cambodia, which C intends to acquire from September 2005 to April 2006 from September 2006.

US$ 20,000,000 ( approximately KRW 2 billion; hereinafter “instant loan”) with the acquisition fund of 22 times

2) The Plaintiff and B did not repay the above loan, and the Plaintiff and B transferred all of their share in the C-ownership shares to the Plaintiff without any defects in the company’s articles of incorporation and Cambodia’s law, and C signed an agreement with the Plaintiff to resolve the obligations of the Plaintiff with respect to the purchase and development of the land in the gue pension project (Evidence 5).

3) The Plaintiff invested USD 1,575,00 on November 21, 2006, and around that time D (hereinafter “D”) as a local corporation of Cambodia (hereinafter “D”).

) The Plaintiff established the following: (a) on January 17, 2007, 140,000 US dollars was additionally invested; and (b) on January 17, 2007, the Plaintiff owned all D’s shares.