1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. Details of the instant disposition

A. On November 20, 1989, the Plaintiff was established and engaged in the civil engineering and construction business. B, a joint representative, retired on December 20, 2010, applied the rules on retirement allowances for officers by the resolution of the general meeting of shareholders (hereinafter “instant retirement allowances rules”), and paid to B on December 24, 2010 totaling KRW 3,500,000 for retirement allowances and special merit pay KRW 261,60,000 for retirement allowances and special merit pay for 3,50,000 for retirement allowances (hereinafter “instant retirement allowances, etc.”) and paid corporate tax by including them in deductible expenses at the time of filing a return of corporate tax for the business year 2010.

B. The Defendant, on August 8, 2013, notified the Plaintiff of the amount of bonus of KRW 3,067,680,000 and KRW 261,60,000 as retirement allowance under Article 44(4)2 of the Enforcement Decree of the Corporate Tax Act, on the ground that “this case’s retirement allowance provision for specific executives cannot be deemed to be a legitimate retirement allowance payment provision stipulated by the articles of incorporation pursuant to the delegation of Article 44 of the Enforcement Decree of the Corporate Tax Act, and the special bonus was paid only by a resolution of the general meeting of shareholders without objective and specific calculation and does not constitute retirement allowance under the Corporate Tax Act.” The Defendant, on the ground that “the act of payment of the instant retirement allowance constitutes wrongful calculation under Article 52 of the Corporate Tax Act.”

(hereinafter referred to as the “instant disposition”). C. The foregoing notice of correction and notification of corporate tax and notice of change in income amount are referred to collectively.

On October 11, 2013, the Plaintiff appealed to the Tax Tribunal, but the Tax Tribunal dismissed the Plaintiff’s request on December 10, 2013.

[Reasons for Recognition] Facts without dispute, Gap evidence 1, 2, 6 (if available, including branch numbers; hereinafter the same shall apply) and Eul evidence 3.