1. All of the plaintiff's claims are dismissed.

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

1. Details of the disposition;

A. The Plaintiff, who is a stock company that manufactures and sells semiconductors, etc., granted its executives and employees stock options to purchase new stocks issued by the Plaintiff at a predetermined price (as a pre-determined price) (hereinafter “new stocks stock options”).

B. Some of the Plaintiff’s executives and employees (hereinafter “instant executives and employees”) exercised a stock option from 2011 to 2013 business years. At the time of filing a corporate tax return for each business year, the Plaintiff did not include the amount equivalent to the gains from the exercise as indicated below (the amount calculated by deducting the exercise value at the market price of new stocks at the time of the event; hereinafter “the gains from the exercise of this case”) as deductible expenses.

(units: 5,166,319,580 4,359,394,600 570,434,680

C. The Plaintiff: (a) deemed that the amount equivalent to the instant event marginal profit was deductible expenses under the Corporate Tax Act; (b) deemed that the amount equivalent to the instant event marginal profit to the instant executives and employees constituted the same amount of expenses; (c) subsequently, on March 24, 2017, the Plaintiff returned the reduced amount of corporate tax by reducing the corporate tax base for the business year 201 to KRW 5,166,319,58,295,150; (d) the refund of the reduced amount of tax; (c) the amount of corporate tax for the business year 2012 to be reduced to KRW 4,359,394,60; and (d) the amount of corporate tax for the business year 2013 to be reduced to KRW 479,53,400; and (d) the amount of corporate tax for the business year 2013 to be refunded to the Defendant (hereinafter “instant claim for correction”); and (d) the Defendant rejected the claim for correction (hereinafter “instant claim”).

On August 25, 2017, the Plaintiff appealed to the Tax Tribunal, but the Tax Tribunal dismissed the Plaintiff’s request on January 30, 2018.