The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Regarding ground of appeal No. 1

A. Before the former Corporate Tax Act was amended by Act No. 12166, Jan. 1, 2014

c. The amendment of the Corporate Tax Act:

Article 63(1) of the former Corporate Tax Act (amended by Act No. 11128, Dec. 31, 2011) provides that a domestic corporation shall pay the amount calculated by dividing the amount of tax calculated as corporate tax for the immediately preceding business year by the number of months in the immediately preceding business year and multiplying by 6 the amount of tax calculated as corporate tax for the pertinent business year for six months from the date of commencing the relevant business year. Meanwhile, Article 55(1) of the former Corporate Tax Act (amended by Act No. 11128, Dec. 31, 2011) provides that “where the corporate tax rate of a domestic corporation for the business year that commences during the period from January 1, 2010 to December 31, 201 exceeds 20 million won, 20 million won (hereinafter “former tax rate”).

Article 55(1) of the amended Corporate Tax Act, amended by Act No. 11128, Dec. 31, 2011, effective January 1, 2012, provides for “where the tax base is more than 200 million won but not more than 20 billion won, 20 million won (20/100 of the amount exceeding 200 million won)” (hereinafter referred to as “amended tax rate”) and “where the tax base exceeds 20 billion won, 3.98 million won (20/100 of the amount exceeding 20 billion won)” (hereinafter referred to as “amended tax rate”).

2) Article 26 of the Addenda (hereinafter “instant supplementary provision”) provides that the supplementary provision shall be referred to as “instant supplementary provision.”

When calculating the interim prepayment tax for the business year that commences after January 1, 2012, pursuant to Article 63 (1).