1. The defendant against the plaintiff:

(a) Of the disposition of each corporate tax stated in the Schedule 1 of the Attached Disposition.

1. Details of the disposition;

A. The Plaintiff and the overseas subsidiaries are companies running businesses such as the manufacture and sale of passenger cars, passenger cars, freight cars, etc. The Plaintiff and the overseas subsidiaries established a foreign subsidiary as indicated in the attached Table. They constitute a foreign related party under Article 2(1)9 of the former Adjustment of International Taxes Act (amended by Act No. 6779, Dec. 18, 2002; Act No. 1126, Dec. 31, 201).

B. From 2006 to 2011, the Plaintiff received payment guarantee and payment guarantee fees from the said overseas subsidiaries to the financial institution, and received 0.15% of the amount of payment guarantee from the said subsidiaries as payment guarantee fees. The details are as follows: (a) the Plaintiff’s fee rate column and the term “payment guarantee fee” column in attached Table (B).

C. Tax adjustment 1) The National Tax Service’s “the arm’s length price determination model for payment guarantee fees for overseas subsidiaries” around 2012 (hereinafter “National Tax Service model”).

A) The Defendant developed the fee rate. The Defendant calculated the difference between the “payment guarantee fee fee calculated according to the National Tax Service model” and the “payment guarantee fee calculated according to the National Tax Service model” and the “payment guarantee fee received by the Plaintiff” as the adjusted amount of income. D. Each of the Defendant’s dispositions was amended by Act No. 6779, Dec. 18, 2002; accordingly, the Defendant issued each of the following dispositions in accordance with Article 4(1) of the former Adjustment of International Taxes Act (amended by Act No. 11126, Dec. 31, 201) on the ground that the “payment guarantee fee calculated according to the National Tax Service model was the difference between the “payment guarantee fee fee received by the Plaintiff” and the “payment guarantee fee received by the Plaintiff.”