The relevant tax authority imposed corporate tax on LG Electronics and Hyundai Heavy Industries for illegally subsidizing affiliates, in connection with a foreign branch taking out a loan with a domestic corporation guaranteeing the payment and receiving a payment guarantee fee from the foreign branch. Lee & Ko represented the above companies and is seeking cancellation of imposition of the corporate tax. In particular, this case was rested on a policy to impose tax on companies that did not include the payment guarantee fee in its gross income, which was based on the model developed in 2012 by the National Tax Service that estimates the normal price of a payment guarantee fee. This case is attracting attention since the relevant tax authority is imposing tax on numerous companies based on the above model and many cases with the same issue are ongoing nationwide.