1. On September 2, 2013, the Defendant’s disposition for imposition of the attached Table 1 (including additional tax) against the Plaintiff shall be revoked.

Facts of recognition

The Plaintiff’s status was established on January 15, 199 and operated the manufacture and sales business of Kabbles and other basic weapons compounds. The Plaintiff became a small and medium enterprise pursuant to the proviso of Article 2(1) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 20544, Jan. 11, 2008; hereinafter the same) in excess of 100 billion won for the first time in the business year of 2006.

Upon filing a corporate tax return for 2008 and 2009, the Plaintiff filed a tax return with the Defendant applying the special tax reduction or exemption under Article 7 (1) of the former Restriction of Special Taxation Act (amended by Act No. 8852, Feb. 29, 2008) by applying the grace period under the main sentence of Article 2 (2) of the former Enforcement Decree of the Restriction of Special Taxation Act.

The Defendant’s disposition imposing corporate tax on the Gwangju regional tax office held 6.75% of the Plaintiff’s shares in the Plaintiff’s parent company in the Call Forum Holdings Liber (Clobian LC). As the Plaintiff is an enterprise belonging to a business group subject to a business group subject to a business group subject to a business group subject to a business group subject to a restriction on mutual investment under Article 9 of the Monopoly Regulation and Fair Trade Act (hereinafter “Fair Trade Act”), Article 2(2)3 and (1)3 of the former Enforcement Decree of the Restriction of Special Taxation Act, Article 3 subparag. 2 [Attachment 2] of the former Enforcement Decree of the Framework Act on Small and Medium Enterprises (amended by Presidential Decree No. 20260, Sept. 10, 2007; hereinafter “OCI”), the Plaintiff ordered the Plaintiff to collect corporate tax for the business year 2008 and 209 of the Special Tax Reduction and Exemption for the reason that the grace period under subparagraph 2 of the attached Table 2 of the former Framework Act on Small and Medium Enterprises.

Accordingly, on September 2, 2013, the Defendant issued an order by the National Tax Service to the Plaintiff on September 2, 2013, KRW 3,217,087,280 of corporate tax for the business year 2008, KRW 1,851,969,020 of corporate tax for the business year 209, KRW 8,634,340 of special rural development tax.