1. The Defendant’s corporate tax of 1,844,779,500 won for the business year of 2005, which was January 12, 201 with respect to the Plaintiff and the Defendant’s corporate tax of 1,84,779,500 won, July 12, 2011.

1. Details of the disposition;

A. On December 6, 1995, the Plaintiff is a corporation incorporated pursuant to the “Private Investment Act in Infrastructure (hereinafter “Private Investment Act”) for the purpose of constructing, managing, and operating the New Airport Expressway in the Seoul Metropolitan Area (hereinafter “instant road”) (hereinafter “instant project”).

(F) On June 16, 200, the trade name of the plaintiff was changed from new Airport Highway Co., Ltd. to New Airport Highway Co., Ltd.

On December 24, 2003, the Plaintiff entered into a senior loan agreement with 7 teachers' mutual aid associations, etc. to raise business funds, and borrowed 840 billion won at a fixed rate of 9% from the Korea Development Bank as 7.39% fluctuation rate. On the same day, the Plaintiff borrowed 170 billion won from the Korea Development Bank as 7.39% fluctuation rate. On January 30, 2013, the Plaintiff entered into a subordinate loan agreement with the Korea Teachers' Mutual Aid Association, Samsung Life Insurance, Samsung Fire and Marine Insurance, T&S Marine Insurance, T&S life insurance, Korea Life Insurance, Korea Bank, Korea Bank, and Korea Road Infrastructure Fund (hereinafter "the subordinate owners of this case") with a fixed rate of 13.9% fixed rate.

(hereinafter “instant subordinated loan”). C.

On May 201, the Board of Audit and Inspection requested the National Tax Service to audit the actual state of ex post facto management of public-private partnership projects from around September 2010 to November 201, 201, and to investigate the appropriateness of the interest rate on subordinated loans by private investors. Accordingly, the Central Tax Office calculated the market price of subordinated loan interest rate at 11.27% (=9% 0.65%) based on the Plaintiff’s senior loan interest rate based on the Plaintiff’s senior loan interest rate at 9% and 1.62% of the subordinated premium market price (i.e., 9%). The Plaintiff borrowed the instant subordinated loan from shareholders at 13.9% from the related parties lacking economic rationality, and determined that the Plaintiff’s borrowing of the instant subordinated loan from shareholders at 13.9% constitutes wrongful calculation.

Accordingly, the defendant shall enter into subordinate agreements with the plaintiff and specially related persons.