1. On March 11, 2015, the Defendant rendered corporate tax (including additional tax) for the business year 2011 against the Plaintiff on March 11, 2015, out of KRW 2,243,725,502.

1. Details of the disposition;

A. The Plaintiff is a local public enterprise established by investing 100% of Gyeongnam-do in accordance with Article 146 of the Local Autonomy Act and Article 49 of the Local Public Enterprises Act for the purpose of contributing to the improvement of the welfare of Do residents of Gyeong-do and the development of local communities through local development projects

B. On February 28, 2001, the Plaintiff entered into an agreement on the management and operation of the roads of the window tunnel, which was the result of collecting tolls from December 1, 2000 to December 31, 201. On September 9, 2005, the Plaintiff entered into an agreement that changed the collection period from December 1, 2000 to July 31, 201, pursuant to the rate of tolls for the window tunnel (existing KRW 1,000 to KRW 50,00) between the Gyeongnam-do and the Gyeongnam-do.

C. On October 6, 2010, Gyeongnam-do reduced the existing toll collection period from July 31, 2014 to December 31, 2010. From January 1, 2011, the tolls of the Changwon tunnel was free of charge.

Meanwhile, after the date of termination of the right to manage the toll road of the Changwon Tunnels at the time of the declaration of corporate tax in 2011, the Plaintiff appropriated expenses of KRW 1,366,385,427 (i.e., the amount of KRW 1,094,842,427 (i.e., repair cost, insurance premium, personnel expenses, etc.) paid by the Plaintiff as deductible expenses (hereinafter “instant expenses”).

E. However, the director of Busan Regional Tax Office, as a result of the Plaintiff’s tax investigation, found that ① the period for collecting tolls for the Changwon Tunnels under the Convention entered into with Gyeongnam-do was as of July 31, 2014, but the collection period was reduced on December 31, 2010 due to the reduction of tolls, and thus, the collection period cannot be recovered as of December 31, 2010. As such, the amount of unpaid investment cost of KRW 3,061,87,00 (in the settlement of accounts, the amount of unpaid investment cost on the settlement of accounts for revenue and expenditure of accounting firms) was recovered from Gyeongnam-do (hereinafter “instant issue”) and ② the Gyeongnam-do would bear the cost of free toll tunneling.