1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of the disposition;

A. On September 5, 2006, Plaintiff A Co., Ltd. (hereinafter “Plaintiff”) established on October 30, 2002 for the main purpose of real estate development advice, etc. on September 5, 2006, Plaintiff B, the representative director of the Plaintiff Co., Ltd. (hereinafter “Plaintiff”) and C Co., Ltd. (hereinafter “C”) respectively for the main purpose of business operation. At the time of the business year 2008, Plaintiff Co., Ltd owns 40% for the shares of Plaintiff Co., Ltd., 40% for the Plaintiff, 40% for the Plaintiff, and 20% for C Representative D.

B. The director of the Central Regional Tax Office of China conducted a tax investigation of C from June 2012 to 2010 with respect to the taxable period subject to the investigation from 2008 to 2010. Since C received services from the Plaintiff Company, C paid the service amount of KRW 220 million in 2008 and KRW 59 million in 2009,000 (hereinafter collectively referred to as “the total amount of dispute”) to account as a loan that is not a service price, and notified the Defendant as the taxation data upon obtaining a written confirmation from C representative Director D that it was not reflected in the corporate tax return cost.

C. On July 1, 2012, the Defendant added the amount of dispute to the value-added tax base upon the notice of the result of the tax investigation by the director of the Central District Tax Office, and included the amount of dispute to the income of the Plaintiff Company, and notified the Plaintiff Company of the change in the amount of income by disposing of the amount of dispute as a bonus and treating it as the income of the Plaintiff Company in 2008.

(hereinafter referred to as “instant disposition” in total, including the imposition of value-added tax and notice of change in income amount.

The Plaintiff filed an objection, but dismissed on September 27, 2012, and the appeal was dismissed by the Tax Tribunal on January 8, 2013.

[Ground of recognition] Facts without dispute, Gap evidence 1-1, 2, 3, Gap evidence 3, 10, Eul evidence 1-2, and the purport of the whole pleadings

2. This.