1. The Defendant’s value-added tax amounting to KRW 1,015,541,350 on April 26, 2017 for the second term of 2013 against the Plaintiff (including penalty tax).

1. Details of the disposition;

A. The Plaintiff is a company established for the purpose of the engineering service business of automobile parts, the wholesale business of electric tools, etc., and the Plaintiff is a subsidiary in which the B GmbH (hereinafter “instant parent company”) as a German corporation has invested 100% of the equity interest.

B. At the time of the plaintiff, the company that entered into a sales support contract with the parent company of this case is C, which was merged with the plaintiff company on December 31, 2015.

Around November 1989, the parent company of this case entered into a sales support contract with the parent company of this case under which the Plaintiff provided various marketing and business management services, including domestic customer information, domestic market trends, and customer inclination surveys, and provided the parent company of this case with sales support services under the above contract.

The contracting parties to the sales support contract shall agree to the following: C Co., Ltd., the contract for the D (Postal Number E) and B) D (Postal Number E) (hereinafter referred to as the "trustee") of the Yeongdeungpo-gu, Gyeonggi-do, Gyeonggi-do, the Republic of Korea permanent establishment in the Republic of Korea in the Republic of Gyeonggi-do (hereinafter referred to as the "KOB") contract:

Article 1 (Purpose of Sales Support Contract)

1. The purpose of this sales support contract is to set the terms of the contract between the delegated person and the delegating person.

From the past, the delegated person and the delegated person have established a business relationship in the form of support by the delegated person for the sale of contract products for customers in this area.

However, as the demand of the customer who wishes to be a partner with influence within this region that can promptly respond to the request of the customer increases, the mandator shall from now to now be entitled to negotiate the delegating product on behalf of the delegating in the OEM-Motor vehicle parts sales sector and enter into the contract in the name of the delegating.

The delegated person shall provide a series of services to the customer and the mandator in accordance with the terms and conditions of this Agreement.

2...