1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

1. Details of the disposition;

A. The Plaintiff is a non-profit domestic corporation established on December 9, 1997 pursuant to Article 9 of the former Act on the Employment Improvement, etc. of Construction Workers (amended by Act No. 6848, Dec. 30, 2002) for the purpose of conducting mutual-aid projects, such as paying mutual-aid money to construction workers as beneficiaries in order to stabilize the employment and promote the welfare of construction workers.

B. The Plaintiff’s request for the correction of corporate tax for the business year 2010 and the Defendant’s request for the correction of corporate tax for the business year 2007 through 2010 against the Plaintiff was filed with the Plaintiff on May 25, 2012, the Plaintiff filed a request for correction to refund KRW 273,712,670, which was withheld interest income of KRW 1,443,965,937 at the tax base return on May 25, 2012, and was not included in deductible expenses as a reserve for non-profit domestic corporations under Article 29 of the former Corporate Tax Act (amended by Act No. 10423, Dec. 30, 2010; hereinafter the same).

However, pursuant to Article 62(1) of the former Corporate Tax Act and Article 99(2) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 22577, Dec. 30, 2010), the Defendant: (a) deemed that the interest income that was not reported by a corporation cannot be included in the tax base by filing a revised return, return after the due date, correction, etc.; (b) the Plaintiff refused to file a request for correction as of May 25, 2012 on the ground that the said interest income cannot be included in the tax base and deductible expenses because it did not report the amount at the time of filing a corporate tax for the business year 2010; and (c) further, (d) was included in the interest income that the Plaintiff erroneously applied to the interest income that should be attributed to other business years; and (e) was included in the corporate tax for the remaining

The corresponding amount of interest income that should be attributed to other business years in the business year.