1. The Defendant’s KRW 1,106,471,980 among the Plaintiff and KRW 1,005,883,620 among them, shall be from June 1, 2007, and KRW 100,58,360.

1. Basic facts

A. The status of the parties, etc. 1) the status of the parties, etc. Dacific L.P. (hereinafter referred to as “CVPAP L.P.”) for the Asia-Pacific Partnership Affairs

A) The partnership is a limited partnership established in Kindo. 2) The Hoveler LC (hereinafter referred to as “AI”) established in the United States of America is a corporation established in the United States of America, 20% of each of the 20% shares of Travelers, a corporation located in the United States of America, and the Hocific Lud. (hereinafter referred to as “CSAP”), a corporation located in Hong Kong, owns 60% shares of each of the 60% shares of each.

3) CVCPAP L.P. and AI are jointly invested in the ratio of 66.67% to 33.33% by 66.67%, and Korea Diriry Lirembour S.A.R.L. (hereinafter “KDL”) as a Luxembourg corporate entity.

4) On December 10, 1999, the management of KDL and DMP P Co., Ltd., a domestic corporation, were jointly invested in the ratio of 88.75% to 11.25% on December 10, 199, and the Republic of Korea Diry Herings N.V. (hereinafter “KH”).

B. On December 21, 1999, KRH is obligated to withhold the Plaintiff’s share purchase and transfer income from the Plaintiff’s share purchase, and the Plaintiff’s share purchase and transfer income from the IMP Co., Ltd. (hereinafter “DMP”) from Denmark Livestock Development Co., Ltd. (3DC)

2) The shares issued by the corporation (hereinafter “instant shares”)

After purchasing the Plaintiff, on July 20, 2005, the Plaintiff sold KRW 17 billion to the Plaintiff, thereby obtaining gains from transfer of KRW 12,374,617,464. 2) The Plaintiff was obligated to withhold corporate tax on the capital gains from transfer of the said stocks pursuant to Article 98(1)4 of the former Corporate Tax Act (amended by Act No. 7837 of Dec. 31, 2005). The corporate tax amount to be withheld is the lesser of the amount equivalent to 10/100 of the paid amount or the amount equivalent to 25/100 of the income accrued from transfer, namely, the amount equivalent to 10/100 of the paid amount or the amount equivalent to 10/100 of the paid amount (hereinafter “capital gains from transfer”).

3. On the other hand, the Plaintiff is a Belgium corporation, the transferor, which is the Republic of Korea.