1. The plaintiff's claim is dismissed.

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

Basic Facts

The Plaintiff is a domestic corporation for the purpose of the export and import business of petrochemicals, by-products, and raw materials, and B (B; hereinafter referred to as “B”) and C (C; hereinafter referred to as “C,” and “B, etc. along with B, etc.) are corporations incorporated in Hong Kong for the Plaintiff’s overseas business.

The Seoul Regional Tax Office, based on the Defendant, issued a tax investigation for each business year from 2008 to 2012 (hereinafter “instant tax investigation”) around August 28, 2013, based on the following investigation, to notify the Plaintiff of the amount of KRW 1,571,71,715,240 of the total amount reverted to the representative’s entertainment expenses out of the total amount reverted to the representative’s 684,017,693 of the total amount reverted to the overseas income from bonus overseas, among the total amount reverted to the Hong Kong corporation’s business in Korea.

(1) Total amount of tax to be paid for a business year (additional Tax) (2) 208 1,074,275,654 won (165,586,743 won) 636,490,345 won 437,785,303,872 won (150,067,658 won) 257,358,4333 won 45,430 won 643,917,50 won (61,260,260,76666), 205, 208, 230 won, 413,50 won (1,260,766 won) 413,258,3638,2964,257,3639,257,295,3638,294,257,297,365,294,

(hereinafter “instant taxation disposition”). On September 30, 2013, the Plaintiff paid all corporate tax of KRW 1,561,856,370 according to the instant taxation disposition.

[Ground of recognition] Facts without dispute, Gap's statements in Gap's evidence 1 through 3 (including branch numbers; hereinafter the same shall apply), plaintiff's assertion of the purport of whole pleadings.