1. The imposition of corporate tax and additional tax on November 1, 2012 by the director of the tax office in North Korea, as stated in attached Form 1, against the Plaintiff.

1. The plaintiff was established in Korea in 1993 in order to carry out business activities, such as domestic sales brokerage, sales of parts, repair business, etc. of the ship engines produced and sold by the Bala Group as an affiliated company of the Bala Group, which is a business group with its head office in Finland.

The Lartman Group is organized by the World Trade Organization (hereinafter referred to as the “Wartsla Corporation”) in a way that it controls Wartsla International Litlance (hereinafter referred to as the “Wartsla International Litlance”) by holding shares, and by holding 100% of the Plaintiff’s shares, it is organized in a way that controls several subsidiaries over the world of the 70th day of the sales brokerage, parts, repair business, etc. of ship-use engines sold by the Group as shown in the Plaintiff.

On November 15, 1995, the Plaintiff entered into the Rotterdam and the service contract (hereinafter “instant service contract”) and paid a total of KRW 1,598,304,898 in the service cost to the Rotterdam from 2007 to 2011, and paid corporate tax by including it in the deductible expenses.

However, the director of the regional office of Busan Regional Tax Office, after conducting a tax investigation on the plaintiff, determined that the service charges that the plaintiff paid to the plaintiff to the plaintiff for the Bazine was distributed to the Bazest in spite of the fact that the plaintiff did not actually receive the service from the Bazine, and that the profit was distributed to the Bazest in the absence of the service from the Bazine. On November 10, 2012, the director of the regional office of Busan Regional Tax Office notified the plaintiff of the change in the amount of income that the income amount from 2008 to 2012 for the year to which the Bazest was reverted

(hereinafter “Disposition of Notification of Changes in Income Amount”) and the director of the tax office North Northern District Tax Office on November 1, 2012.