1. On July 15, 2016, the Defendant: (a) KRW 86,019,432, out of global income tax of KRW 163,367,195 for the taxable year 2012, against the Plaintiff.

Details of the disposition

B Co., Ltd. (hereinafter referred to as “foreign corporation”) was a corporation that has been engaged in the business of manufacturing vessel parts located in Gyeong-gun, Chungcheongnam-gun, Chungcheongnam-gun, which was closed ex officio on October 31, 2012.

A non-party corporation filed a non-party corporation tax without filing a corporate tax for the business year 2012, and the head of the competent tax office, around February 2014, disposed of KRW 534,00,000 as a bonus for D, the representative director of the non-party corporation, on the balance sheet of the business year 2011, which was not recovered until the closure of the business.

However, the director of Busan Regional Tax Office confirmed that the provisional payment-related interest amounting to KRW 2,794,520 (principal 375,000,000) was reverted to the Plaintiff when conducting a comprehensive audit of the general tax audit of the above loan amount around July 2015, the amount of KRW 534,00,000 and the amount of KRW 32,045,000 for the above loan amount for the business year 2012 was reverted to the Plaintiff and corrected the corporate tax amount of KRW 566,045,00 for the total amount of KRW 32,00,000 for the above loan amount and KRW 566,045,00 for the corporate tax return for the business year 201.

On November 2015, the head of the competent tax office corrected the corporate tax for the business year 2012 of the non-party corporation, and notified the Defendant of the assessment data on the income change in the taxable year 2012 to the Plaintiff. On July 15, 2016, the Defendant decided and notified the Plaintiff of the global income tax amount of KRW 246,222,920 (additional penalty) for the taxable year 2012.

(hereinafter “instant disposition”). The Plaintiff filed an objection on September 30, 2016, but was dismissed on December 20, 2016, and filed a request for examination with the Commissioner of the National Tax Service on March 14, 2017.

The Commissioner of the National Tax Service shall make a request for examination by the plaintiff on June 2017.