The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Regarding ground of appeal No. 1

A. Article 25(1) of the former Corporate Tax Act (amended by Act No. 10423, Dec. 30, 2010; hereinafter the same) provides that entertainment expenses paid by a domestic corporation for each business year in excess of the sum of the following amounts shall not be included in the calculation of losses in calculating the income amount for the relevant business year. Paragraph (5) provides that entertainment expenses mean entertainment expenses, school expenses, recompense, and other similar expenses paid by a corporation in connection with its business regardless of the pretext thereof.

In light of the language and purport of these regulations, if the other party is a person related to the business among the expenses paid by the corporation for the business and the purpose of expenditure is to promote the smooth progress of transaction by promoting friendship with the business related persons through the act of entertainment, etc., such expenses shall be deemed as entertainment expenses under Article 25(5) of the former Corporate Tax Act.

(See Supreme Court Decision 2008Du12320 Decided January 27, 201). B.

citing the reasoning of the first instance judgment, the lower court, citing the reasoning of the first instance judgment, as follows: ① the Plaintiff was a corporation established by investing 100% of the Korea Tourism Promotion Corporation established on September 6, 2005 by obtaining permission for casino business under the Tourism Promotion Act, and operated a casino exclusively for foreigners (hereinafter “instant casino”) at the Seoul Gangnam-si, Seoul Hero hotel, Busan Hero Hotel hotel, and Busan Packer hotel; ② the Plaintiff provides an existing overseas customer with futures, alcoholic beverages, light survey expenses, etc. from 2006 to 2009 to 2009 through the local office of Japan and China, marketing strategy office of its head office, and the mater belonging to the new market development team.