1. On February 13, 2017, the Defendant filed an application for rectification of KRW 14,002,638,468, corporate tax against the Plaintiff for the business year of 2015.

1. Details of the disposition;

A. The Plaintiff is running a business that produces and sells DNA splay (TV, monitor, set-in, etc.)-related products using technology, such as TFT-L CD (s) and OLD (organic or luminous diode).

B. The Plaintiff established a research institute (B) and hired researchers from a doctoral and doctoral degree, and had them work exclusively for the research and human resources development expenses. At the time of filing a corporate tax return in 2011, the Plaintiff applied for the tax credit of KRW 14,02,638 (the amount equivalent to KRW 85,43,341,138 (the amount equivalent to the labor expenses of tin and doctoral degree 85,443,341,138) for the research and human resources development expenses paid to researchers from the above doctoral and doctoral degree as at the time of filing a corporate tax return in 2011, pursuant to Article 10 of the former Restriction of Special Taxation Act (amended by Act No. 111133, Dec. 31, 2011; hereinafter “former Restriction of Special Taxation Act”). However, the amount of the said tax credit for the research and human resources development expenses incurred in the business year until the business year 2014 was not deducted.

C. Meanwhile, Article 132(1)3 of the former Restriction of Special Taxation Act excluded the amount of tax credit for research and human resources development expenses equivalent to the amount of labor expenses for tin and doctoral degree from the minimum tax credit. However, Article 132(1)3 of the Restriction of Special Taxation Act (amended by Act No. 111133, Dec. 31, 201; hereinafter “amended Restriction of Special Taxation Act”) provides that the amount of tax credit for research and human resources development expenses equivalent to the amount of labor expenses for tin and doctoral degree of non-small and medium enterprises shall be the minimum tax.

In filing a corporate tax return for the business year 2015, the Plaintiff filed a corporate tax deduction carried forward pursuant to Article 144(1) of the Restriction of Special Taxation Act, which had not been deducted for the business year 2011, including the key tax amount of the instant case, and the Plaintiff at the time.