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 is a corporation that manufactures and sells automobile parts.

The plaintiff, a foreign subsidiary of China, has the mandatory forest electronic company (hereinafter referred to as "Gangsung") as its subsidiary.

The plaintiff is a parent company that holds 100% of the shares in the Gangseo forest.

B. From December 1, 2015 to March 16, 2016, the Director of the Daejeon Regional Tax Office conducted a consolidated investigation of corporate tax against the Plaintiff, and notified the Defendant that the Plaintiff should be taxed by excluding KRW 1,235,809,478 from 2010 to 2014, by regarding the amount appropriated as personnel expenses for the employees dispatched from Gangwon Forest as non-business expenses, and 623,005,490 as income from the disposal of defective raw materials, and 162,50,000 as income from the disposal of defective raw materials.

C. Accordingly, on April 12, 2016, the Defendant notified the Plaintiff of KRW 195,971,860 of the corporate tax in 2011, KRW 123,096,810 of the corporate tax in 2012, KRW 113,151,350 of the corporate tax in 2013, and KRW 110,031,720 of the corporate tax in 2014 (hereinafter “instant disposition”), and among them, the portion related to personnel expenses for the employees dispatched to the Gangwon Forest was KRW 104,48,290 of the corporate tax in 2011, KRW 81,981,980 of the corporate tax in 2012, KRW 74,966,280 of the corporate tax in 2013, KRW 605,470 of the corporate tax in 2014, KRW 75,470 of the corporate tax in 2014.

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on July 15, 2016, but was dismissed on November 22, 2016.

[Ground of recognition] Unsatisfy, Gap evidence Nos. 1, 2, and 3 (including branch numbers), the purport of the whole pleadings

2. The plaintiff's assertion

A. Of the Plaintiff’s local subsidiaries, the river management among the Plaintiff’s local subsidiaries is a company that directs, supervises, and supervises 100% of the Plaintiff’s 10% of the Plaintiff’s Chinese branch or local factory’s quality of products produced in the river management is closely related to the increase of Plaintiff’s profits.

The employees who were dispatched by the plaintiff to the Gangwon Forest are not only local subsidiaries.