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 spent total of KRW 33,159,80,234 ( KRW 9,831,683,381, KRW 23,328,116,853, etc.) in order to acquire a ship, which is a business asset in the business year of 2011 and 2012, which is a corporation operating an international combined freight forwarding business. (hereinafter “instant amount of ship investment”).

B. At the time of filing a corporate tax return for the business year 201 and 2012, the Plaintiff filed an application for the tax credit for employment-generating investment under Article 26(1) of the former Restriction of Special Taxation Act (amended by Act No. 11614, Jan. 1, 2013; hereinafter “Special Act”) on the instant ship investment amount without filing an application for the tax credit for employment-generating investment.

C. On January 22, 2015, the Plaintiff filed a request for the rectification of corporate tax to the effect that the request for the rectification of the reduction of corporate tax for the business year 2013 is based on the carry-over portion of the amount that was not deducted in the business year 2012, pursuant to the provision on the tax credit for investment for the said amount of ship investment for the pertinent business year 585,454,160, corporate tax for the business year 2012, corporate tax for the business year 940,271,060, and corporate tax for the business year 2013.

In order to be eligible for tax credit for employment-generating investment, the Defendant shall be a small or medium enterprise prescribed in Article 2(1) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 24368, Feb. 15, 2013; hereinafter “Enforcement Decree of the Restriction of Special Taxation Act”). The Plaintiff rejected the Plaintiff’s request for correction on October 19, 2015 on the ground that the Plaintiff did not meet the requirements for tax credit for employment-generating investment because annual sales for each business year of 2011 and 2012 are at least KRW 100 billion.

(hereinafter “Disposition Rejecting Correction of this case”). 【No dispute exists, entry of Gap evidence Nos. 1 and 2, and the purport of the whole pleadings

2. The entry in relevant Acts and subordinate statutes (attached Form 1);

3. Whether the disposition rejecting the correction of the instant case is lawful, the Defendant receives from the owner of the instant goods in the business year 2011 and 2012.