1.The judgment of the first instance shall be modified as follows:

On April 8, 2011, the defendant Kambi Tax Office Co., Ltd.

1. The grounds for the court’s explanation on this part of the plaintiffs’ assertion are as stated in the corresponding part of the judgment of the court of first instance except for the dismissal of the judgment of the court of first instance as follows. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

Nos. 14 to 18 of the judgment of the court of first instance 1) Plaintiff Punocar Korea Co., Ltd. (which was established on Dec. 14, 199 as a trade name, career sirens Co., Ltd.) and run the manufacture and sales business of Puhool products, which are alcoholic beverages, changed to the current trade name around September 2008.

hereinafter referred to as "Plaintiff PRI"

around May 9, 2006 and around May 9, 2006, a career sirens Trade Co., Ltd. (it was established on December 14, 1999 and has been engaged in the import and sales business of mine and sirens, which are alcoholic beverages.

hereinafter referred to as "JBIC"

) The Plaintiff Punoo Korea Co., Ltd. (established on December 31, 1992, and has been engaged in the import and sale of the Scarine and Round Products, which are alcoholic beverages.

hereinafter referred to as "Plaintiff PRK"

A) All corporations are specially related to Perno S.A. Decision 4. Following the first instance court’s decision, joint indirect expenses, such as joint personnel expenses and expenses for maintaining offices, among the joint expenses at the end of each fiscal year, are based on the total sales of the two companies. According to the above contract, the Plaintiffs shared joint expenses for flue products based on the sales of fluore products. Joint expenses for fluore products are shared based on the sales of fluor products. Joint expenses for fluore products are divided based on the sales of fluor products. The difference between the actual expenses and the common expenses disbursed by the Plaintiffs is received, and the sales tax invoice is settled by the method of issuing the sales tax invoice

2. Whether each of the dispositions of this case is legitimate

(a) An entry in the attached Form 4 of the relevant Acts and subordinate statutes;

B. 1. The application of Article 26 subparagraph 5 of the former Corporate Tax Act is sought.