1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On November 20, 2007, the Plaintiff received incentives 1,706,249,174 (hereinafter “the instant revenue amount”) from Nonparty Company pursuant to Article 8(3) of the “Contract for Supervision and Joint Production” (hereinafter “Agreement”) from Nonparty Company with respect to the instant film, and paid KRW 206,456,151, which was calculated by applying the simple expense rate of 87.9% of the business category of “ordinary film production” to the Defendant on May 31, 2011, with respect to the instant film, the Plaintiff paid KRW 206,456,151, which was calculated by applying the simple expense rate of 87.9% of the business type of “ordinary film production.”

B. On October 8, 2013, the Defendant: (a) considered the instant income amount as the income amount of KRW 788,085,865 calculated by applying the simple expense rate of 66.8% (basic rate)/53.5% (excess rate) of the business category of “motion picture supervision”; and (b) additionally corrected and notified the Plaintiff of global income tax of KRW 275,41,270 (including additional tax) in addition to the amount of income in 2010.

(hereinafter “instant disposition”). C.

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on January 8, 2014, but was dismissed on July 2, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, 5, Eul evidence Nos. 1 to 3, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion is merely a joint producer of the motion picture of this case who performs supervisory duties as part of the production work. As such, the simple expense rate of the category of “general motion picture production” shall apply to the income amount of this case. Even if the Plaintiff performed supervisory duties separately from the production work, the simple expense rate of the category of “general motion picture production” and the category of “motion picture supervision” shall be applied in proportion thereto.

(b) Entry in the attached statutes of the relevant statutes;

C. The fact-finding of the non-party company is mainly engaged in the production of a general film.