1. The Defendant’s corporate tax of KRW 57,798,539 (including additional taxes) for the business year 2009 that the Plaintiff on November 23, 201 and the business year 2010.

1. Details of the disposition;

A. On September 9, 1998, the Plaintiff is a juristic person established under the Private Investment Act (hereinafter “Private Investment Act”) for the purpose of constructing and operating private investment projects in the Dogsan tunnel.

B. From September 15, 2010 to November 5, 2010, the Board of Audit and Inspection conducted an inspection of the ex post facto management of private investment projects by guaranteeing minimum import, and requested the National Tax Service to investigate whether the interest rate on subordinated loans is appropriate.

C. Accordingly, around July 201, the Defendant: (a) examined the Plaintiff’s appropriateness of calculating interest on subordinated loans in the business year 2009 and the business year 2010; and (b) determined that “the Plaintiff paid 20% interest rate to the Plaintiff upon borrowing KRW 26.6 billion from shareholders on January 16, 2009 is a special transaction with the lack of economic rationality.”

In accordance with Article 52 of the Corporate Tax Act (amended by Act No. 10423, Dec. 30, 2010; hereinafter the same shall apply) on November 23, 201, the Defendant: (a) imposed an amount exceeding 8.5% of the interest rate on subordinated loans in the business year 2009 and the business year 2010 (including additional taxes) (the amount exceeding 2,93,287,671, the business year 2009: 2,93, 287, 671, the amount exceeding 8.5% of the interest rate on subordinated loans (the amount of KRW 3,059,000 for the business year 2010: 3,059,000, the amount of KRW 761,786,630 (including additional taxes) of the corporate tax in the business year 209; and (b) imposed an additional tax

(The Defendant imposed corporate tax of KRW 774,669,050 for the business year 2009, and corporate tax of KRW 816,319,560 for the business year 2010, but imposed corporate tax of KRW 816,319,560 for the business year 209, as the additional tax was re

On February 17, 2012, the Plaintiff filed a request for adjudication on February 17, 2012, and on August 16, 2012, the Tax Tribunal rendered a decision that “The Tax Tribunal shall re-examine whether 20% of the parties to the subsequent priority loan are subject to the wrongful calculation under Article 52 of the Corporate Tax Act, and make correction according to the result.”

E. In the course of reinvestigation, the Plaintiff is from 7.65% to 8.5% of the base interest rate.