2. The costs of lawsuit are assessed against the plaintiffs.

A. The Defendant’s imposition disposition of value-added tax (1) C Co., Ltd. (hereinafter “C”) entered into a contract with D, E, and F (hereinafter “G”) on October 2005 and November 2009 to entrust the purchase and sales of goods to conduct a special sales business, such as C’s point driving business, with G.

(2) On September 16, 2009, H Co., Ltd. (hereinafter “H”) was established for the purpose of wholesale and retail business of promotional products, miscellaneous products, computers and peripheral devices, household goods, etc., and entered into a supply contract with C to supply goods to a customer designated by C. Since then C designated H as the purchasing entity of H, the supply transaction of goods was conducted in the GH C order.

(3) However, with a view to raising funds to use for repayment of individual debt, G actually operated the transaction of circular transaction in which G is supplied to “GH C” in the original transaction order by using the fact that G is fully entrusted with the purchase business and the sales business from “CG”, and H made a transaction in which G sells goods to “GH C” in the order of the transaction. H concealed the circular transaction structure and pretended as having directly supplied goods to “A” in accordance with the order of a customer company, such as credit card company, etc., and made a transaction in which “A” receives goods from “H” and “A” and “A” receives goods from “A” and “A” and “B” receives goods from “A” and “B” through “A”.

(4) According to the above transaction, H is issued a purchase tax invoice of KRW 21,494,00,518 of the supply value during the taxable period from February 2, 2009 to February 2, 2010, and H is KRW 22,963,949,916 of the supply value to C.