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1. The Defendant’s remaining remaining amount of losses in the business year 2006, which was in the business year 2010, to the Plaintiff on July 1, 2013.
Reasons
1. Details of the disposition;
A. Daegu-U.S.-U. Daegu-U.S.-U.S.-U.S. 1) Daegu-U.S.-U.S. Project (hereinafter “instant project”).
(1) The former Public-Private Partnership Act (amended by Act No. 6776 of Dec. 11, 2002; hereinafter “Private Investment Act”) provides for the following:
(2) Article 4 Subparag. 1 of the Act provides that “1. Infrastructure is built, managed, and operated on an expressway with a total length of 82.1k km from the Dong-gu to the Dong-si, Daegu-si, by means of “BTO’s ownership belongs to the State or a local government at the time of the completion of the construction of the infrastructure and the recognition of the project operator’s right to manage and operate the infrastructure for a certain period of time (BTO).” (2) The Plaintiff is a company established under the Private Investment Act for the purpose of the instant project on December 8, 199.
3) On December 17, 2007, the Plaintiff entered into a senior loan agreement with four companies, such as the Hanhae Infrastructure Investment and Financing Company (the shareholder), and borrowed KRW 970,100,000,000 (hereinafter referred to as “first priority loan”). The Plaintiff borrowed KRW 970,100,000,000 (hereinafter referred to as “first priority loan”).
(A) On November 28, 2008, the National Pension Service, the Korea Infrastructure Corporation, and the Korea Infrastructure Fund, concluded a subordinate loan agreement with the Korea Infrastructure Corporation, and KRW 597,231,00,000 among which KRW 300,300,000 (A) took loans of KRW 12-20% per annum, KRW 296,931,000 per annum, and KRW 20-40 per annum (B) borrowed the loans of KRW 597,231,00,000 per annum at the interest rate of KRW 20-40 per annum (hereinafter “the loans of KRW 597,231,00,000”).
B) The Board of Audit and Inspection (MRG: MRG: payment of compensation equivalent to the difference between the estimated operating income and the actual operating income as agreed in the concession agreement) shall be conducted by checking the following: (a) the Defendant’s interest rate on subordinated loans; (b) the determination of the tax base of corporate tax as of February 2, 2012; and (c) the determination of the appropriateness of the interest rate on subordinated loans by private investors to the National Tax Service.