1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff (B Co., Ltd. before the change on December 1, 2013) was an unlisted corporation that produces double steel. From 2008 to 2010, the Plaintiff paid the following general bonuses and special bonuses to C, a representative director and a major shareholder, in addition to ordinary salaries.

(units: 170,421,750, 340,843,50, 500, 912, 120, 200, 252, 963, 709, 385,281, 690, 790, 780, 380, 983, 547, 860, 754, 111, 240, 202, 2010, 2082, 310, 402, 62064, 62064, 6348, 090, 016, 512, 710, 756, 7501, 57, 501, 50, 510, 510, 510, 610, 610

B. On September 8, 2005, the Plaintiff established a limited liability company (hereinafter “overseas subsidiaries”) with 100% of the Plaintiff’s 100% equity shares in China, and provided a payment guarantee when an overseas subsidiary obtains a loan from a financial institution.

C. The Seoul regional tax office conducted a tax investigation with the Plaintiff from November 21, 2013 to February 14, 2014, and then notified the Defendant that the amount of income should be adjusted after deducting the normal payment guarantee fee reported by the Plaintiff from the gross income of each corresponding year after calculating the amount of income of each business year on the grounds that the special bonus paid by the Plaintiff to C constitutes excessive expenses beyond the bonus provisions of executive officers under Article 26 of the former Corporate Tax Act (amended by Act No. 10423, Dec. 30, 2010).

According to the notification of the Seoul Regional Tax Office, the Defendant adjusted the amount of income as follows, and notified the payment of corporate tax of 463,447,490 won in March 27, 2014, and the amount of corporate tax of 452,262,680 won in April 1, 2014, and corporate tax of 2010 KRW 282,217,70 in corporate tax of 2010.