1. The Defendant’s corporate tax for 2010 consolidated business year (including additional tax amounting to KRW 47,186,678) filed with the Plaintiff on December 2, 2013.

In light of the above legal principles, the above corporate tax law violates the corporate tax law to remove the asset appropriated in accordance with the "transaction between consolidated corporations", since it is the removal of all net asset changes recognized as transactions with a third party other than consolidated corporations as well as consolidated corporations.

(b) The details of the relevant statutes are as shown in the attached statutes.

C. 1) Determination 1) Article 18-3 of the Corporate Tax Act outlined of the system for exclusion from taxable income for import dividends, and Article 17-3 of the former Enforcement Decree of the Corporate Tax Act provides that where a profit-making domestic corporation receives dividends from another domestic corporation in which it has invested more than a certain percentage of shares, an amount calculated according to the following accounting-1 out of the said dividends shall be excluded from gross income.

The calculated-type 1 = Revenue dividends 】 Revenue dividends 】 Non-Inclusion ratio in gross income exclusion ratio * Non-Inclusion ratio in gross income ratio: 30%, 50%, and 100% apply according to the equity ratio of another domestic corporation * borrowed interest 】 borrowed interest of the relevant domestic corporation 】 (a drop number of the book value of stocks of another domestic corporation x non-Inclusion ratio) / (a drop number of the book value of stocks of the relevant domestic corporation 】 (a drop number of the book value of stocks of the relevant domestic corporation x non-Inclusion ratio) / The above provisions were prepared to prevent the relevant domestic corporation from re-payment of corporate tax by excluding

At this time, some of the interest on borrowings paid by the relevant domestic corporation must be deducted from the amount of gross income of the imported dividends. This prevents a corporation with heavy liabilities from acquiring stocks of another domestic corporation or using loans to acquire stocks of another domestic corporation, and prevents double benefits that would be earned if the relevant domestic corporation includes interest paid in deductible expenses and exclude the imported dividends from gross income.