Real estate rental income and profit-making recognition period, such as fees for the use of cemeteries, for the sale of cemeteries;

It is reasonable to view that the park cemetery user fee has the nature of real estate rental income, and since the profit is realized at the time of the burial, it shall be included in the gross income, and the advance paid before the performance of the contract shall not be deemed the time of supply.

Article 40 of the Corporate Tax Act, Article 71 of the Enforcement Decree of the Corporate Tax Act, Article 19-7 of the General Rules of the Income Tax Act, Article 9 of the Value-Added Tax Act, Article 22 of the Enforcement Decree of the Value-Added Tax Act (Time of supply for services)

1. Of the disposition imposing corporate tax and value-added tax on March 16, 2004 by the defendant against the plaintiff on March 16, 2004

(a) the portion of the corporate tax of the 1998 374,972,020 won;

B. The portion of each value-added tax exceeding each amount mentioned in the separate sheet for calculating the amount of value-added tax shall be revoked.

2. The plaintiff's remaining claims are dismissed.

3. Two minutes of the lawsuit shall be borne by the plaintiff, and the remainder shall be borne by the defendant.

Purport of Claim

The imposition of corporate tax and value-added tax on March 16, 2004 by the defendant against the plaintiff on March 16, 2004 shall be revoked.

1. Details of the disposition;

A. The plaintiff's status

(1) As a result, the Ministry of Unification decided to divide a park cemetery site into a person who has financial capacity among foundations established by the citizens of the Republic of Korea, in accordance with the purport of the project to create uniform movables, which provides a place to fluence of the families of separated families on October 1992. As a result, the Plaintiff received a park cemetery site within a unified movable property and obtained a permission for establishment from Gyeonggi-do on September 6, 1995 for the purpose of developing, maintaining, and managing a park cemetery for the people of separated families, etc. for the purpose of acquiring a park cemetery site within a unified movable property and obtaining a permit for establishment from the Gyeonggi-do on September 6, 1995.

(2) The Ministry of Unification requested that the purchaser of a cemetery in a park in a unified movable property shall be an incorporated foundation established by the people of the people of the Republic of Korea, taking into account the initial purpose of the promotion of the project, which is to provide a place to the deceased families of the separated families with a view to aboveing the deceased, but this association was established on January 13, 1993 by the ○○○ Park Co.,, Ltd. (hereinafter referred to as the “O○○ Park”) with a view to failing to meet the requirements for the establishment of the incorporated foundation at the time of the sale of the cemetery in a park in a unified movable property.

(b) Creation of a park cemetery and the invitation of its members;

(1) On June 26, 1993, the non-party corporation was recommended by the Ministry of Unification as a participant in the tender for the supply of the site for the facility site for the Uniform Movables and Park. On June 30, 1993, the non-party corporation entered into a contract for the supply of the land located in ○○○○○○○○○○○○○○, a site for the facility site for the park, ○○○○○○○○○○, a site for the facility site for the park, and delivered the intent to authorize the foundation after purchase of the land and completion of the facility at ○○○○○○○○○○○○, a site for the facility site for the park, to 19,213, and from December 28, 1998 to October 19, 201, each stage of graveyard 10,917 (total period of 30,130,130) was established.

(2) The eligibility of the members of the non-party corporation is granted to the persons from North Korea, the persons of distinguished service to unification, and the persons of distinguished service to North Korea. The non-party corporation recruited members of the cemetery except for the cemetery cemetery for the persons of distinguished service to unification and the persons of distinguished service to North Korea (including their lineal ascendants and descendants in the family register and their lineal ascendants and descendants). At the time of recruitment, the non-party corporation received the entrance fee for the purpose of appropriating the payment of the land price and the expenses needed for graveyard creation and graveyard management (the non-party corporation entered into a contract for graveyard use at the time when the deceased member was buried and received the entrance fee and the management fee of the cemetery). Specifically, the non-party corporation received the total amount of KRW 36,24,609,00 from 198 to 202 as the entrance fee and the value-added tax on the park cemetery usage fee, park management fee and park management expenses, and the detailed details are as follows:

(unit: Won)

Classification Year

Total guidances

1998

199

200

201

202

Total guidances

36,244,609,000

40,801,000

16,350,696,000

5,956,590,200

6,278,190,000

7,218,332,000

General

Flags

(6/30)

30)

User Fees

5,659,845,686

100,062,686

1,253,102,680

1,405,305,880

1,404,656,050

1,496,718,390

Management Expenses

6,145,105,742

108,608,468

1,360,123,019

(3,132,00)

1,525,940,109

(4,002,00)

1,525,234,500

1,625,199,646

VAT

615,510,572

10,860,846

136,012,301

152,594,011

152,523,450

162,519,964

guidance.

12,419,462,000

219,532,000

2,749,238,000

3,083,840,000

3,082,414,000

3,284,438,000

Mali half-years

(12/3)

30)

User Fees

11,694,516,996

100,854,410

7,035,559,806

1,309,112,170

1,456,315,120

1,792,675,490

Management Expenses

11,027,845,460

109,467,810

5,968,998,358

(4,872,00)

1,421,48,937

(3,480,000)

1,581,328,073

1,946,562,282

VAT

1,102,784,544

10,946,780

596,899,836

142,148,893

158,132,807

194,656,228

guidance.

23,825,147,000

21,269,00

13,601,458,000

2,872,750,000

3,195,776,000

3,933,894,000

(3) Meanwhile, the contents of the Membership Regulations of the non-party legal entity are members of the non-party legal entity, and the non-party legal entity has the right to use only one cemetery base, which will be established and operated by the non-party legal entity, and the membership fees paid by the member automatically replaced with the usage fees and the cost of creating the cemetery determined by the plaintiff, and only the principal shall be refunded to the non-party legal entity before the use of the cemetery, and the business for the establishment and operation of the plaintiff, the business for the establishment and operation of the cemetery, and other projects incidental thereto shall be administered by the non-party legal entity and transferred to the plaintiff through due process. In addition, the rights of the members shall not be transferred to another legal entity, and the membership rights shall not be terminated when the member using the cemetery discontinues the cemetery, or when the duration of the cemetery expires by other Acts.

(c) Tax treatment for admission fees;

(1) The non-party corporation did not recognize the membership fee received from the members as profit before transferring it to the liquidation of the non-party corporation, and appropriated it in the advance account, which is the subject of the debt, to the Plaintiff, and only if the deceased members are buried, the entire amount of the membership fee received from the relevant member has been transferred to

(2) On the other hand, the Plaintiff reported and paid corporate tax by appropriating the amount equivalent to the usage fees of a park cemetery among the membership fees transferred upon the death of a member as the total amount of profit in the business year to which the date of burial belongs, and by appropriating the amount divided according to the period of use of the cemetery (30 years or 60 years) as the profit accrued in each business year. The Plaintiff also reported and paid the value-added tax on the amount corresponding to the management expenses of a park cemetery by appropriating the amount divided according to the period of use of the cemetery.

D. The defendant's imposition of each disposition

(1) In calculating the corporate tax base, the Defendant revised the amount of income for each business year by deeming that the time when the profit and loss accrued was erroneously recognized as profit in proportion to the use of the instant park cemetery from the time of burial. In addition, in the case of the park cemetery management expenses, since the time when the non-party corporation receives the expenses is the time of supplying services, the value-added tax was reported in full at the time of receiving the expenses, and thus, the non-party corporation deemed the non-party corporation as the actual owner of the park cemetery business and notified the non-party corporation of the corporate tax and the value-added tax as of June 2, 2003. However, the Defendant revoked the disposition of imposition of the above corporate tax and the value-added tax as of December 26, 2003 upon the decision of the National Tax Tribunal on December 26, 2003.

(2) After that, in accordance with the purport of the above decision of the National Tax Tribunal, the Defendant again notified the Plaintiff of the corporate tax and value-added tax to the Plaintiff by deeming the Plaintiff as the actual agent of the park cemetery business. In the case of corporate tax, the Plaintiff presumed that the business year to which the date of burial belongs belongs as the date when the Plaintiff received membership fees from the non-party corporation (the date when the Plaintiff received the cemetery usage fees), i.e., the business year to which the date of burial belongs, and imposed value-added tax on the difference between the amount reported by the Plaintiff and the total amount of the park cemetery usage fees out of the membership fees transferred from the non-party corporation or received directly from the non-party corporation as the gross income for the business year to which the date of burial belongs (hereinafter “instant disposition imposing corporate tax”). On the contrary, in the case of value-added tax, the time when the non-party corporation received the membership fees (the time of receiving the management fees from the plaintiff for the cemetery cemetery), and on the difference between the amount reported by the Plaintiff as the value of supply in the relevant taxable period.

E. On April 26, 2004, the Plaintiff was dissatisfied with the disposition of imposition of the pertinent corporate tax and value-added tax, and requested a judgment to the National Tax Tribunal, but the National Tax Tribunal dismissed the said judgment on August 28, 2006.

[Ground of recognition] Each entry of Gap 1 through 6, 9, 10 evidence, Eul 1 through 11 (including each number), and the purport of the whole pleadings

2. Whether the disposition of imposition of the corporate tax of this case is legitimate

A. The plaintiff's assertion

(1) Since the use fee of the instant park cemetery is revenues from the establishers of the relevant grave as the cost for the use of the relevant grave without transferring the ownership of the relevant cemetery after purchase of the land, it constitutes real estate rental income. In the case of the use fee of the park cemetery for the business year 1998, the profit and loss should be calculated in accordance with the corporate accounting standards first applied principles. In the case of the use fee of the park cemetery after the business year 1999, the profit and loss should be calculated in accordance with the corporate accounting standards first applied principles. In the case of the use fee of the park cemetery after the business year 199, there is no defect under

(2) According to the Defendant’s assertion, if the total amount of the facility fee of this case is recognized as gains for the business year which includes the date of burial, the deductible expenses expected to occur in the future cannot be recognized as being attributed to the business year which includes the date of burial, and thus, it should be paid corporate tax by recognizing excessive profits in the lump sum. On the other hand, while the corporate tax of this case is to be paid for the period following the completion of burial, since only the expenses such as personnel expenses and the expenses for the maintenance and repair of the park cemetery were incurred during the period after the burial was completed, and thus, the amount of corporate tax paid in advance may not

(b) Related statutes;

[Corporate Tax]

Article 40 (Business Year of Profit and Loss)

(1) The fiscal year of accrual of earnings and losses of a domestic corporation shall be the fiscal year which includes the date on which the concerned earnings and losses are settled.

(2) Necessary matters concerning the scope of the business year of accrual of earnings and losses under paragraph (1) shall be prescribed by Presidential Decree.

[Enforcement Decree of the Corporate Tax Act]

Article 71 (Business Year in which Rents and Other Profits and Losses accrue)

(1) In the application of the provisions of Article 40 (1) and (2) of the Act, the fiscal year of accrual of earnings and losses from the lease of assets shall be the fiscal year which includes the date falling under any of the following subparagraphs: Provided, That in the settling of accounts, where any amount equivalent to the rental fee for any period that has already passed and expenses corresponding thereto are appropriated as profits and losses for the concerned fiscal year and the payment period of the rental fee exceeds one year, an amount equivalent to the rental fee for the period that has

1. Where the date of payment of rent is determined by a contract, the payment date;

2. Where the payment date of rents is not determined by a contract, etc., the payment date;

【former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 17457 of Dec. 31, 2001)】

Article 71 (Business Year in which Rents and Other Profits and Losses accrue)

(1) In the application of the provisions of Article 40 (1) and (2) of the Act, the fiscal year of accrual of earnings and losses from the rental of assets shall be the fiscal year which includes the date under each of the following subparagraphs: Provided, That in the settling of accounts, where any rental fee for any period that has already passed is appropriated as profits and losses for the concerned fiscal year, it shall be the fiscal year of the appropriated earnings and

1. Where the date of payment of rent is determined by a contract, the payment date;

2. Where the payment date of rents is not determined by a contract, etc., the payment date;

【former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 15970 of Dec. 31, 1998)】

Article 36 (Business Year of Profit and Loss)

(1) The business year which includes the date on which the gross income and the deductible expenses under the provisions of Article 17 (1) and (4) of the Act are confirmed shall be as follows:

4. In case where the whole or part of assets is leased, the amount of money to be received as the rent for the concerned business year and each subsequent business year according to the terms of the contract and the corresponding expenses shall be included in the calculation of earnings and losses for the concerned business year;

【former Enforcement Decree of the Corporate Tax Act (wholly amended by Presidential Decree No. 15970, Dec. 31, 1998)】

Co., Ltd.

Article 1 (Enforcement Date) This Decree shall enter into force on January 1, 199.

Article 8 (Application Cases to Business Year, etc. of Profit and Loss) (1) The amended provisions of Articles 68, 69 and 71 shall apply from the portion of the beginning of sale, transfer, lease, provision of services, etc. of assets, etc. in the business year that commences first after this Decree enters into force.

[Common Provisions of Corporate Tax Act]

November 2, 15-11.2 (Disposition of Burial Fees and Graveyard Creation Costs) The usage fees and grave construction costs of a corporation operating a park cemetery project shall be treated as follows:

1. The rent received in return for the establishment of the right to grave base shall be included in the gross income in calculating the income amount for the business year in which the amount was received or expected to be received, as it is impossible to return it, and as the period of existence of the right to grave base expires

2. The cost of graveyard creation (excluding the land value) is the corresponding cost to the land rent received at the time of graveyard sale, and the amount corresponding to the corresponding cemetery sale portion shall be included in the calculation of the income amount for each business year.

[Common Provisions of Income Tax]

Article 19-7 (Classification of Types of Real Estate Sales Business, etc.)

(2) The development of a cemetery and the establishment of the right to grave base and the collection of rent, etc. from the establisher of a grave shall constitute a substitute for real estate.

(3) Where a business operator who has established the right to grave base has no obligation to return it as a royalty, and the period of using the right to grave base has not been fixed or has not been permanently used, it shall be included in the gross income in the taxable period including

C. Determination

(1) The legal nature of the park cemetery usage fee

The following circumstances acknowledged based on the above evidence, namely, ① the Plaintiff’s operating rules and the notice of invitation of members stipulate that the period of use of a cemetery shall be 30 years or 60 years, and the Act on Funeral Services, etc. provides that the period of use shall be 60 years for the installation of a grave established after January 13, 201 (it shall not be permanent due to the fact that the term of use is prescribed as the establishment of a charnel house after cremation after the expiration of the period of establishment in the Membership Regulations). ② According to Article 7 of the Plaintiff’s Membership Regulations, in principle, a member’s rights cannot be transferred to others, and if a member who uses a cemetery discontinues his cemetery, his membership shall be extinguished. Thus, if the agreement on the use of a cemetery of this case is deemed as a contract having the nature similar to the sale of the base of the cemetery, it is difficult for the relative of the cemetery to provide reasonable explanation on the prohibition of transfer and termination of membership rights, and the right to use the cemetery of this case cannot be seen as the right to use the cemetery of this case.

(2) The time of inclusion of the instant park cemetery usage fee in gross income

(A) The portion of corporate tax for the business year 1998

According to Article 36 subparagraph 4 of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 15970, Dec. 31, 1998) concerning the time when the use fees of the park cemetery of this case constitute the rental income of real estate, and where the whole or part of the assets are leased, it shall be included in the gross income and deductible expenses for the pertinent business year and the subsequent business year according to the terms and conditions of the contract. Thus, as regards the use fees of the park cemetery of this case, it is reasonable to include the amount divided according to the period of use of the park cemetery in the gross income for the pertinent business year, and thus, it is unlawful to impose the corporate tax for the Defendant for the pertinent business year of 198 on the premise that the total amount of the use fees of the park cemetery of this case should

(B) From the business year 1999 to the business year 2002 portion of corporate tax

According to the relevant Acts and subordinate statutes, the period of attribution of earnings and losses from the lease of assets shall be the business year to which the date of payment belongs if the date of payment of rent is determined by the contract, etc., and if the payment of rent is not made by the contract, the date of payment shall be the business year to which the date of payment belongs: Provided, That in settling accounts, an amount equivalent to the rent for the period which has already passed and the corresponding expenses are appropriated as earnings and losses for the relevant business year, respectively, and in the case of long-term lease of at least one year after 202, an amount equivalent to the rent for the period which has already passed without any appropriation of profits and losses and the corresponding expenses shall be deemed as earnings and losses for the relevant business year. The plaintiff's assertion that the period of payment of rent exceeds one year under the proviso of Article 71 (1) of the Enforcement Decree of the Corporate Tax Act is not applicable to the case where the whole period of payment of rent exceeds one year, and the defendant's actual profits and losses are not applicable to the period of sale under the premise of the former Enforcement Decree of the Housing Act (amended by Presidential Decree No. 15970.

(C) Therefore, this part of the Plaintiff’s assertion is with merit within the above recognition law.

(3) Whether the principle of responding to profit cost is violated

On the other hand, the principle of response to profit costs under the Corporate Tax Act refers to the expression of realized profits and costs, expenses, and losses related to such profits in the fixed period or subject matter, and when profits are confirmed, the timing of recognition of profits depends on whether to include the corresponding costs and expenses, etc.., and the time of recognition of profits vary depending on whether to determine expenses. The time of the burial as the time of inclusion of the park cemetery usage fees in the gross income of this case is the time of inclusion of the park cemetery usage fees of this case. The profit from the lease of the assets has already been realized at the time of burial. The cost corresponding to the park cemetery usage fees of this case has already been determined at the time of burial as the cost of graveyard creation, etc., and the plaintiff collects separate park cemetery usage fees in response to the expenses such as management expenses incurred in the relevant business year continuously during the period of existence of the contract to use the park cemetery usage fees, in light of the fact that the plaintiff imposed corporate tax by considering the time of transfer of membership fees from

3. Whether the disposition of value-added tax in this case is legitimate

A. The plaintiff's assertion

(1) Since the provision of the park cemetery management service of this case constitutes the ordinary provision of services under subparagraph 1 of Article 22 of the former Enforcement Decree of the Value-Added Tax Act (amended by Presidential Decree No. 17460 of Dec. 31, 2001; hereinafter the same), even if the management expenses for the park cemetery are paid in advance, it should be deemed that the provision of services, which is the time of provision, is completed when the provision of services, is completed, i.e., when the provision of services, which is the time of provision of each service,. Even if the management expenses for the park cemetery management service of this case are not the ordinary provision of services under subparagraph 1 of Article 22 of the Enforcement Decree of the Value-Added Tax Act, the fees for the park cemetery management service of this case constitute the real estate rental income under the classification of income, and the non-party corporation receives the management expenses for the park cemetery for a certain period (30 years or 60 years from its members, together with the registration fees for the park cemetery of this case.

(2) Since the non-party corporation did not provide any service to its members at the time of receiving membership fees from its members on behalf of the Plaintiff, the imposition of the value-added tax by deeming the time of supply for the instant park cemetery management expenses as the time of receiving membership fees from its members is unlawful.

(b) Related statutes;

[former Value-Added Tax Act (amended by Act No. 7007 of Dec. 30, 2003)]

Article 9 (Transaction Time)

(2) The time when services are supplied shall be the time when services are provided or goods, facilities or rights are used.

(3) Where an entrepreneur receives all or part of the price for goods or services before the time provided in paragraph (1) or (2) arrives, and at the same time issues a tax invoice provided in Article 16 or a receipt provided in Article 32 with respect to such price, the time of such issuance shall be deemed the time of supply for the goods or services concerned, respectively.

(4) Matters necessary for the time of supply under paragraphs (1) and (2) shall be prescribed by Presidential Decree.

【former Enforcement Decree of the Value-Added Tax Act (amended by Presidential Decree No. 17460 of Dec. 31, 2001)】

(Time of Supply for Services) The time of supply for services under Article 9 (2) of the Act shall be as follows: Provided, That if the time of supply for services supplied before closure of business arrives after such closure, the time of supply for services shall be deemed the time of supply for such services:

1. In the case of ordinary supply, when the offer of the service is completed;

2. Where services are supplied on the basis of the standard payment, interim payment, long-term installment or on other terms, or services are continuously supplied on the basis of which the unit of supply cannot be partitioned, when each part of the price is to be received;

3. Where the provision of services is completed and the value of supply is determined, in case where the provisions of subparagraphs 1 and 2 are not applicable.

4. In the case of supply value calculated under Article 49-2 (1) and (3), the date on which the preliminary return period or taxable period ends.

Article 49-2 (Special Cases concerning Calculation of Tax Base for Real Estate Lease Services)

(3) Where a business operator supplies real estate rental services over two or more taxable periods and receives the fees in advance or in later installments, the tax base shall be the total sum of each taxable period divided by the number of months in the relevant contract period. In such cases, Article 51 (2) of the Enforcement Decree of the Income Tax Act shall apply mutatis mutandis

C. Determination

(1) The legal nature of the instant park cemetery management services

On the other hand, the park cemetery management fees of this case are completely different from the park cemetery usage fees of this case for a certain period of time from the park cemetery usage fees of this case. Thus, the park cemetery management services of this case do not have the same nature as the real estate lease services of this case under Article 49-2 of the Enforcement Decree of the Value-Added Tax Act. Rather, the park cemetery management services of this case constitute a continuous supply of services that cannot be divided into a unit of continuous management of the cemetery. Thus, the first argument of the plaintiff on the premise that the park cemetery management services of this case constitute the "ordinary supply of services" under Article 1 of the former Enforcement Decree of the Value-Added Tax Act or the "real estate lease services under Article 49-2 (3)" under Article 49-2 (3) of the former Enforcement Decree

(2) Time of supply for the management of the Park Cemetery

According to the relevant Acts and subordinate statutes, the ordinary time of transaction of the service under the Value-Added Tax Act refers to the time when the provision of the service is completed, or when the service is continuously supplied by a unit of supply, the time of supply for the service concerned is determined to receive each part of the price. "The time of supply for the service is determined to receive each part of the price deemed the time of supply for the service" refers to the time when the service is supplied in whole or in part after the contract for the supply of the service is concluded. Thus, in the case of money transaction of an advance nature received prior to the execution of the contract for the supply of the service, the time of such money transaction cannot be deemed

In light of the nature of advance payment as the condition of the provision of cemetery management services in cases where a member dies and a member is buried in the future, the imposition of the value-added tax in this case on a different premise cannot be deemed as the time of supply for the management services of the park cemetery. Thus, the imposition of the value-added tax in this case on a different premise is unlawful, and the second argument of the plaintiff pointing this out is with merit.

However, in the case of park cemetery management expenses for a graveyard that the plaintiff received directly at the time of burial, the supply of the management services was practically commenced at the time of burial, and in that it agreed to receive the cemetery management expenses at the time of burial, the time of burial, which is the time of receiving the entire management expenses, the payment for the management services, shall be the time of supply for the park cemetery management services. Therefore, the value-added tax amount corresponding to the park cemetery management expenses for the cemetery cemetery in the disposition of value-added tax in this case shall be lawful.

(3) Calculation of a legitimate amount of tax

The legitimate tax amount payable by the Plaintiff as value-added tax from the first to the second period of 2000 for the legitimate tax amount payable by the Plaintiff from the first period of 199 to the second period of 2000 shall be deducted from the value-added tax base for the park cemetery management expenses received by the non-party corporation from its members in the relevant taxable period and calculated a legitimate tax amount,

4. Conclusion

Therefore, the portion of the value-added tax in excess of the amount stated in the "reasonable tax amount" column of the corporate tax amount of 374,972,02,020 and the "reasonable tax amount of value-added tax" column of the attached sheet for the business year of 1998 among the disposition imposing corporate tax and value-added tax of this case shall be revoked. Thus, the plaintiff's claim is justified within the above scope

Details of imposition;

Sub-Items :

Between the world and the world;

tax amount (cost)

legal person:

1998 Business year

374,972,020

199 business year

661,296,180

200 Business year

562,523,740

201 Business year

595,320,340

202 Business year

509,022,240

Consolidateds

2,703,134,520

Value-added Tax

1, 1999

264,867,010

Second Period of 1999

1,107,563,780

1, 200

254,013,500

200 No. 2

27,057,200

Consolidateds

1,853,501,490

Value-Added Tax Calculation Table

1. The first period of 199;

Gu Sector

Reporting (Initial)

G. G. M.S.

Amount of legitimate tax;

Tax Base

3,219,00

6,351,000

Tariff Rates (10%)

10

10

Sales amount

635,100

Additional Tax

296,757

* Additional tax calculation basis

Ministry of Payment;

31,320

Payments: 313,200*10/100

Shin Jin high

265,437

Report: 313,200*1,695 (Number of Days)

Amount of tax credit

321,900

321,900

*5/10,000

Notice Tax Amount

609,957

609,957

2. Second period of 199;

Gu Sector

Reporting (Initial)

G. G. M.S.

Amount of legitimate tax;

Tax Base

4,785,000

9,567,000

Tariff Rates (10%)

10

10

Sales amount

478,500

956,700

Additional Tax

409,100

* Additional tax calculation basis

Ministry of Payment;

47,820

Payments: 313,200*10/100

Shin Jin high

61,280

Report: 313,200*1,695 (Number of Days)

Amount of tax credit

478,500

*5/10,000

Notice Tax Amount

478,500

87,300

87,300

3. The first period of 200.

Gu Sector

Reporting (Initial)

G. G. M.S.

Amount of legitimate tax;

Tax Base

29,554,550

3,556,550

Tariff Rates (10%)

10

10

Sales amount

2,955,455

3,355,655

Additional Tax

305,953

* Additional tax calculation basis

Ministry of Payment;

40,020

Payments: 313,200*10/100

Shin Jin high

265,933

Report: 313,200*1,695 (Number of Days)

Amount of tax credit

2,955,455

2,955,455

*5/10,000

Notice Tax Amount

706,153

706,153

4. Second period of 200.

Gu Sector

Reporting (Initial)

G. G. M.S.

Amount of legitimate tax;

Tax Base

67,377,280

70,857,280

Tariff Rates (10%)

10

10

Sales amount

6,737,728

7,085,728

Additional Tax

234,030

* Additional tax calculation basis

Ministry of Payment;

34,800

Payments: 313,200*10/100

Shin Jin high

199,230

Report: 313,200*1,695 (Number of Days)

Amount of tax credit

6,737,728

6,737,728

*5/10,000

Notice Tax Amount

582,030

582,030