1. Corporate tax of 1,332,94,820 and special agricultural and fishing villages tax of 1,332,94,820 and 162,249, which the Defendant provided to the Plaintiff on March 5, 2015.

1. Details of the disposition;

A. The Plaintiff is an affiliated company belonging to an enterprise group, which is a holding company holding company EK.

S&C Co., Ltd. (hereinafter “S&C”) is an affiliated company belonging to an enterprise group E&C case, and the Plaintiff is in the position of a related party as prescribed by Article 87(1)7 of the Enforcement Decree of the Corporate Tax Act.

The plaintiff is an enterprise that manufactures and sells petroleum and chemical products, and SPC is an IT service enterprise that supports the planning of construction and operation strategies of information technology systems, system design, development, construction and operation.

B. Around December 1998, the Plaintiff entered into a service contract for the establishment and operation of the information system (hereinafter “instant contract”). From January 1, 1999 to December 31, 2009, the service period was from January 1, 2009 to December 31, 2009. Of the service amount, the labor cost was calculated based on the daily unit price per month for software technicians published by the president of the Korea Software Industry Association in accordance with the “Standards for Price for Software Business”; based on the government’s notice, the labor cost was calculated based on the monthly unit price per month (M/M (asset/month; hereinafter “unit price notice”) calculated based on the monthly unit price (M/M (asset/month; hereinafter “unit price notice”).

Since then, the instant contract was renewed by December 31, 2020.

In 2009, the Plaintiff paid 34,007,753,474 won in total in return for services for the establishment and operation of the information system under the instant contract.

C. After conducting a corporate tax investigation against the Plaintiff, the director of the Seoul Regional Tax Office: (a) paid the service price at a discounted price from the notified unit price to SPC; and (b) paid the service price to SPC at a non-affiliated company that received the service from SPC; and (c) the Plaintiff.