1. The plaintiff's claim is dismissed.

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

Details of the disposition

After its establishment on October 23, 199, the Plaintiff is a corporation that manufactures, sells, develops, and exports precise taxation, such as L CDs, and operates an export business. The Plaintiff is a corporation that settles accounts on December 31 of each year.

In filing a corporate tax for the business year 2012, the Plaintiff: (a) deemed that it falls under a small and medium enterprise under Article 2(1) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 24368, Feb. 15, 2013; hereinafter the same) and applied for the special tax reduction or exemption of 75,741,096, and the tax credit of 153,225,290; and (b) filed a corporate tax return by applying

On July 11, 2016, the Defendant issued a correction and notification of KRW 279,863,830 (including general under-reported additional taxes and late-payment for arrears) of corporate tax for the business year 2012, on the ground that the Plaintiff’s sales among the Plaintiff and its affiliated company B Co., Ltd. (hereinafter “B”) as of the end of the business year 2012 added up sales among the Plaintiff and its affiliated company B Co., Ltd. (hereinafter “B”), on the ground that the Plaintiff satisfies the requirements for the graduation from small

On August 19, 2016, the Plaintiff appealed and filed a request for a tax trial seeking revocation of the relevant disposition with the Director of the Tax Tribunal. On February 16, 2017, the Director of the Tax Tribunal rendered a decision to dismiss the remainder of the request for a tax trial on the following grounds: (a) on July 14, 2016, the Defendant imposed corporate tax of KRW 279,863,830 against the Plaintiff on July 14, 2016 on the Plaintiff, excluding KRW 115,680 as general under-reported penalty tax.

(2) The Plaintiff’s assertion as to the legitimacy of the instant disposition and the purport of the entire pleadings should be revoked on the following grounds. The Plaintiff’s assertion as to the legality of the instant disposition should be revoked on the following grounds.

The former Enforcement Decree of the Restriction of Special Taxation Act.