1. Corporate local income tax (additional tax) imposed by the Defendant against the Plaintiff on May 9, 2018, on the imposition of KRW 45,143,57.

1. Details of the disposition;

A. As a result of the audit conducted by the Seoul Regional Tax Office from September 14, 2017 to September 29, 2017, the National Tax Service pointed out that the Plaintiff did not impose additional tax on the Plaintiff on the interim dividend of KRW 249,694,260,640 on Company B in 2014 and did not submit the payment record.

B. Accordingly, on March 22, 2018, the head of the Guro Tax Office imposed penalty tax on the Plaintiff pursuant to Article 76(7) of the former Corporate Tax Act (amended by Act No. 12850, Dec. 20, 2016; hereinafter the same) on the Plaintiff, subject to Article 49(1)2 of the former Framework Act on National Taxes (amended by Act No. 14382, Dec. 20, 2016; hereinafter the same), imposed corporate tax for the year 2014 (additional tax on the amount of additional tax).

C. Local tax authorities, including the Defendant, imposed corporate local income tax (additional tax already submitted) on the Plaintiff by applying the tax rate prescribed in Article 103-30(5) of the former Local Tax Act (amended by Act No. 13427, Jul. 24, 2015; hereinafter “instant Local Tax Act”) to the tax rate of KRW 49,298,520, which is the amount of corporate local income tax (additional tax already submitted) to the Plaintiff, and imposed corporate local income tax on the Plaintiff in proportion to the pro rata distribution ratio for each competent local government under Article 88 of the former Enforcement Decree of the Local Tax Act (amended by Presidential Decree No. 26431, Jul. 24, 2015).

On May 9, 2018, the Defendant imposed and notified KRW 45,143,57 of the corporate local income tax imposed on the Plaintiff by applying the proportional distribution ratio of 9.0414 to the Plaintiff.

(hereinafter “instant disposition”) D.

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on August 3, 2018, but was dismissed on December 3, 2018.

[Ground of recognition] Unsatisfy, entry of Gap evidence 1 to 5, purport of whole pleadings

2. The case.