1. The Defendant’s corporate local income tax of KRW 11,651,300 against the Plaintiff on April 18, 2018, and KRW 11,651,300 against the Plaintiff on April 18, 2016.

1. Details of the disposition;

A. The Plaintiff is a domestic corporation whose head office is located in B at both weeks, and is mainly engaged in the business of manufacturing and selling building materials.

B. The Plaintiff has a limited liability corporation (hereinafter “foreign subsidiary”) under Article 57(5) of the former Corporate Tax Act (amended by Act No. 12850, Dec. 23, 2014) in the People’s Republic of China (hereinafter “China”).

C. In filing a corporate tax return for the business year of March 2014, 2015, the Plaintiff: (a) selected the methods of tax credit under Article 57(1)1 of the former Corporate Tax Act (Amended by Act No. 12850, Dec. 23, 2014); and (b) obtained the tax credit of KRW 116,513,032, the amount corresponding to the dividend income, including the tax base, from among the amount corresponding to the dividend income, where the amount corresponding to the dividend income, is included in the gross income of the indirect foreign corporation’s income for each business year of the indirect foreign corporation under Article 57(4) of the former Corporate Tax Act (Amended by Act No. 1522, Dec. 19, 2017; hereinafter the same shall apply) pursuant to Article 15(2)2 of the same Act; and (c) obtained the tax credit of KRW 116,513,032, which was imposed on the income of the foreign company.

In filing a corporate tax return for the business year on March 28, 2017, the Plaintiff: (a) selected a method of tax credit for foreign tax amount; (b) included KRW 174,063,773, which is an indirect foreign tax amount, in the gross income and included it in the tax base; and (c) received the said tax credit of KRW 174,063,773.

E. Meanwhile, in calculating the tax base pursuant to Article 103-19 of the former Local Tax Act (amended by Act No. 14475, Dec. 27, 2016; hereinafter the same), the Plaintiff filed a return on and paid corporate local income tax for the business year 2014 and corporate local income tax for the business year 2016 to the Defendant, and accordingly, filed the return on corporate tax.