1. All of the plaintiff's claims are dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. The Plaintiff, a company mainly engaged in the game program development business and the game service business, operated the game program directly developed at his own expense (hereinafter “self-production game program”) or the game program, etc. acquired the right of use through a contract with another game development business entity (hereinafter “independent game program”) through the Internet, and operated the same in a manner of obtaining import by operating it at home and abroad through the Internet.

On the other hand, the plaintiff did not have a permanent establishment in a foreign country related to the overseas business.

B. From 2009 to 2012, the Plaintiff established a 30 game program development plan and started its development.

Among them, the development of 17 game programs was suspended in the course, one game program was completed, and the sales of the service was poor, and the service was terminated, and seven game programs could create revenue through domestic service.

In addition, some game programs have started in foreign countries and generated income from overseas sources.

C. The Plaintiff determined that the cost of developing its own game programs does not constitute an intangible asset to be recognized as an asset for accounting purposes, and recognized the total amount as the cost at the time of disbursement. At the time of filing and paying corporate tax for each business year from 2009 to 2012, the above accounting cost was appropriated as the deductible expense at the time of disbursement.

Meanwhile, where the former Corporate Tax Act (amended by Act No. 12850, Dec. 23, 2014; hereinafter the same) contains any income generated from overseas sources to the tax base of a domestic corporation, the ratio of the amount of corporate tax (excluding the amount of corporate tax on capital gains on land and other capital gains) calculated by income generated from overseas to the tax base of the relevant business year to the amount of corporate tax (excluding the amount of corporate tax on capital gains from overseas sources