1. The Defendant’s corporate local income tax for the business year 2,070, 134,585 won, and the Defendant’s corporate local income tax for the Plaintiff on September 27, 2016 against the Plaintiff on September 27, 2015.

Details of the disposition

The Plaintiff is a corporation that runs coal production and processing and sales business, overseas resources development business, export and import business, etc., and the consolidated tax return system of consolidated tax return system pursuant to Article 76-8 (1) of the former Corporate Tax Act (amended by Act No. 1522, Dec. 19, 2017; hereinafter the same) is a complete parent company that controls B (hereinafter referred to as “B”), a complete subsidiary, C (hereinafter referred to as “C”), D (hereinafter referred to as “E”), and E (hereinafter referred to as “E”), and is a complete parent company that controls B, C, D, and E (hereinafter referred to as “each subsidiary of this case”). The consolidated tax return system of consolidated tax return pursuant to the consolidated tax return system refers to the method of reporting and paying corporate tax by adding two or more domestic corporations to one tax base and

(Article 1 subparagraph 6 of the former Corporate Tax Act). The Plaintiff and each of the subsidiaries of this case reported business income.

In filing a corporate tax return for the business year 2014, the Plaintiff was not included in E among the subsidiaries of this case.

A tax base was returned to 242,770,580,945 won. Where the amount of income for each business year of a domestic corporation directly paid foreign tax to the Plaintiff is included in dividend or surplus distribution received from a foreign subsidiary, among the amount of foreign corporate tax imposed on the foreign subsidiary's income for each business year, the amount of foreign corporate tax imposed on the foreign subsidiary's income shall be included in the amount of income corresponding to the dividend income (Article 57 (4) of the former Corporate Tax Act), 82,26,180,485 won, and the amount of foreign corporate tax imposed on D directly paid foreign tax amount of KRW 16,079,679,026,569 (hereinafter "the foreign corporate tax amount") plus KRW 94,07,079,026,569 (hereinafter "the foreign corporate tax amount of this case") under Article 57 (1) 1 of the former Corporate Tax Act, and the method of tax credit under Article 15 (2) 2 and 21 of the former Corporate Tax Act.