1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff is a domestic corporation established on November 20, 2006 for the purpose of engaging in the manufacturing of offshore plants, the trial operation of ships, and the manufacturing of related equipment.

The Plaintiff holds shares in B, C, and D (hereinafter collectively referred to as “related companies”) and is in the position of related companies under Articles 2 and 3-2 of the former Enforcement Decree of the Framework Act on Small and Medium Enterprises (amended by Presidential Decree No. 25302, Apr. 14, 2014; hereinafter the same shall apply).

Plaintiff 38,056,848,008 54,753,462,660,660,972,956,706 B (State) 835,136,3224,786,586,585,928 4,543,205,069 C (State) 1,403,630,630,8917,925,547,2759,281,418,13 D (State) for the business year 2014 for the business year 2013

B. The sales from the business year 2012 to the business year 2014 of the Plaintiff and related companies are as follows:

C. The Plaintiff filed a corporate tax return for the business year 2014 and 2015 business year, stating that “The Plaintiff’s sales revenue for the pertinent business year exceeds KRW 100 million, which is the grounds for exclusion from small and medium enterprises as prescribed by the proviso of Article 2(1) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 26070, Feb. 3, 2015; hereinafter the same) but the Plaintiff is subject to the grace period to be deemed a small and medium enterprise pursuant to Article 2(2), and thus, is entitled to benefit from the tax credit under the Restriction of Special Taxation Act.”

On July 3, 2017, the Defendant: (a) calculated pursuant to Article 7-4 of the Enforcement Decree of the Framework Act on Small and Medium Enterprises; and (b) total sales of the Plaintiff and related enterprises are governed by Article 2(1)3 of the Enforcement Decree