When Defendant 1 fails to pay the above fine, the above Defendant shall be confined in a workhouse for the period calculated by converting KRW 2,000,000 into one day.

However, with respect to Defendant 1, the execution of the above imprisonment shall be suspended for three years from the date this judgment becomes final and conclusive.

Defendant 1 shall order the provisional payment of an amount equivalent to the above fine.

The prosecution against the defendant 2 and 3 is dismissed.

No person shall commit an act to submit to the Government a list of total tax invoices by seller under the Value-Added Tax Act without being supplied with any goods or services under the Value-Added Tax Act by entering it falsely.

Nevertheless, Defendant 1 in collusion with the above defendant:

1. On April 26, 2010, the preliminary return of value-added tax was made by Nonindicted Company 1 for the first year 2010 in Pyeongtaek-si Tax Office located in Pyeongtaek-dong, Pyeongtaek-si: (a) Nonindicted Company 1 entered the preliminary return of value-added tax in the first year from January 1, 2010 to March 31, 2010; (b) Non-Indicted Company 2 entered the preliminary return of value-added tax on the aggregate tax invoice for individual suppliers in a false manner as if the supply price was supplied with goods or services equivalent to KRW 851,273,145 during the said period from Nonindicted Company 2; and (c) submit it to the said tax office;

2. On July 26, 2010, Nonindicted Company 1 filed a final tax return on the value-added tax base for the year 2010 at the said tax office: (a) Nonindicted Company 1 was supplied with goods or services under the Value-Added Tax Act between April 1, 2010 and June 30, 2010 by Nonindicted Company 2 and Nonindicted Company 3; (b) on the aggregate tax invoice for individual suppliers, even though the said period was not completed, Nonindicted Company 2 was supplied with goods or services under the Value-Added Tax Act, Nonindicted Company 1 submitted to the said tax office a false statement as if it were supplied with goods or services equivalent to KRW 1,53,93,95 from Nonindicted Company 2, and KRW 568,486,195 from Nonindicted Company 3, and submitted it to the said tax office;

3. On October 25, 2010, upon filing a preliminary return of value-added tax for the second period of 2010 by the said tax office, Nonindicted Company 1 entered the preliminary return of value-added tax in the said tax office on the aggregate of KRW 1,213,453,453,98 won in total from Nonindicted Company 2 and Nonindicted Company 3, even though Nonindicted Company 1 was not supplied with goods or services pursuant to the Value-Added Tax Act from July 1, 2010 to September 30, 2010, the said preliminary return was submitted to the said tax office, after stating as if it had been supplied with goods or services equivalent to KRW 51,452,170 in the aggregate of KRW 1,162,01,818 from Nonindicted Company 3, and submitted it to the said tax office.

1. Examination protocol of the suspect against Defendant 3 by the prosecution, and examination protocol of the suspect against Defendant 1 and Defendant 3 by the prosecution (secondly examination);

1. Each prosecutor’s statement on Nonindicted 4, 5, 6, 7, and 8

1. Each statement of the police interrogation protocol against Nonindicted 8, each police protocol against Nonindicted 8, Nonindicted 4, and Nonindicted 5, and each statement of the police protocol against Nonindicted 4, 8, and 9

1. Each written statement prepared by Defendant 2 and Nonindicted 5

1. Each value-added tax return, a list of total tax invoices by seller;

1. Personal inquiry into the details of the total business of each individual, details of transactions in each passbook, details of transactions in passbook, each Internet banking, details of transactions in passbook, each application for opening of each account, each business registration certificate, each customer transaction certificate, each business registration certificate, each business registration statement, each charter, monthly contract, business registration statement, correction statement, in-house director registration statement, each real estate lease contract, each place of business, each written confirmation, each letter of confirmation, Nonindicted Company 1's benefit statement, written confirmation, each work fact-finding certificate, mail, mail, telephone subscription statement, interview record file and meeting details, investigation report (Attachment to summary order), each investigation report, each contract document, the ledger of the account for human life and current status of input by service company;

1. A written accusation, a written report on completion of investigation into data, each report on value-added tax and sales, and a list of tax invoices by seller (Evidence No. 108 through 111);

Articles 10(3)3 and 30 of the former Punishment of Tax Evaders Act (amended by Act No. 11210, Jan. 26, 2012; hereinafter the same shall apply) of the former Punishment of Tax Evaders Act (amended by Act No. 11210, Jan. 26, 2012);

1. Aggravation for concurrent crimes;

Imprisonment: former part of Article 37, Article 38 (1) 2, and Article 50 of the Criminal Act (Aggravation of Concurrent Crimes in Imprisonment with prison labor as provided for in Article 2 of the Judgment with the most severe Crimes)

A fine: The former part of Article 37 of the Criminal Act and Article 20 of the former Punishment of Tax Evaders Act [the application of Article 38(1)2 of the Criminal Act is excluded, so the amount of fine shall be calculated separately for each crime and added up (see Supreme Court Decision 2009Do3131, Jul. 23, 2009)]

1. Suspension of execution;

Article 62(1) of the Criminal Act

1. Detention in a workhouse;

Articles 70 and 69(2) of the Criminal Act

1. Order of provisional payment;

Article 334(1) of the Criminal Procedure Act

Defendant 1’s transaction with Nonindicted Company 2 and Nonindicted Company 3 (hereinafter “instant transaction”) entered in the list of the total tax invoices by seller of Nonindicted Company 1 (hereinafter “instant transaction”) as indicated in its reasoning, and is not a disguised processing transaction.

2. Determination

A. According to each evidence of the judgment, the representative of Nonindicted Company 2 and Nonindicted Company 3 in the corporate register can be identified through the following circumstances.

(1) Nonindicted Company 2

A) Defendant 1 instructed the superior Defendant 2, who was in office as a director of Nonindicted Company 1 and the superior Defendant 3 who was working for Nonindicted Company 1 as the employee of Nonindicted Company 1 on the lower day in order of 2009, to “the plan to additionally establish and operate a company whose business objective is the temporary work agency on the pretext of a third party as its nominal representative, and to lend the name of the representative director in physical color.”

B) Accordingly, the Defendant 3 requested the name lending to Nonindicted 4, who had been living in the ○ prison around that time, and received the consent.

C) However, Defendant 1 said that Nonindicted 4 was in a physical condition, on the ground that he was in a physical condition.

D) Around that time, Defendant 2 obtained the consent on the name lending from Nonindicted 8’s recipient of basic livelihood (class 6 with physical disability) who was in a relationship with Defendant 1 (class 6 with Defendant 2), and around that time paid KRW 3 million in total to Nonindicted 8 on two occasions with Defendant 1’s approval.

E) On January 6, 2010, Defendant 1 established Nonindicted Co. 2, a company whose business purpose is human resources supply, on the ground that Nonindicted Co. 8 was the sole in-house director on the registry and the sole in-house director on the registry.

F) On January 11, 2011, Defendant 2 was appointed as an auditor of Nonindicted Company 2 on the day of the above establishment, and Nonindicted Company 11, who was working as an employee of Nonindicted Company 1, completed the business registration on behalf of Nonindicted Company 2 on behalf of Nonindicted Company 2.

G) Meanwhile, Nonindicted 4 was released from ○ prison on or around March 2010 and thereafter engaged in daily work in the △△ market located in Daegu. On or around July 2010, Defendant 3 again requested Nonindicted 4 to become a nominal representative director of Nonindicted Company 2, who was requested by Nonindicted 4 to accept the request.

H) On July 7, 2010, Nonindicted 8 resigned from the internal director of Nonindicted Company 2, and on the same day, Nonindicted 4 was registered in the corporate register as being the only internal director of the said company.

I) On July 20, 2010, Nonindicted 4 received KRW 2 million from Defendant 1 to Defendant 1’s name account in return for the name lending.

(2) Nonindicted Co. 3

A) Defendant 1 decided to establish a human resources supply company as one by the above method on the first and second in order of 2010, and ordered the above defendants to re-consign the name of the representative.

B) Accordingly, the Defendant 2 borrowed his resident registration certificate and seal under the pretext that it is necessary for the guarantee related to the business from Nonindicted 9 who had been living in the old at the time through Nonindicted 14, his father, who was his father.

C) On April 5, 2010, Defendant 1, using Nonindicted 9’s resident registration certificate and seal, registered the representative director on the registry as Nonindicted 9, and established Nonindicted 3 Company with the purpose of human resources supply business.

D) Nonindicted 11 was appointed as an auditor on the date of establishment of Nonindicted Company 3, and completed business registration on behalf of Nonindicted Company 3 on May 14, 2010.

E) However, around July 2010, there was a situation in which it was difficult to register Nonindicted 9 as the representative director of Nonindicted Company 3, and Defendant 1 instructed the upper accused to the effect that he would be registered as the representative director of the said company once again.

F) Accordingly, the Defendant 3, through Nonindicted 15, who was at the time at the Yeongdeungpo-gu Station via Nonindicted 15, who was at the time, Nonindicted 5, who was at the time at the time, was her own village, would give KRW 1,00,000 per month to Nonindicted 5, who was in the influence of the Yeongdeungpo-gu Station, “if a corporation is created in the future, it would be paid KRW 1,00,000 per month. Ultimately, tax has been set off, but no more than several years has

G) On July 7, 2010, Nonindicted 9 resigned from the intra-company director positions of Nonindicted Company 3, and Nonindicted 5 was registered as the only intra-company director of Nonindicted Company 3 on the same day.

H) From around that time, Defendant 3 paid a sum of KRW 10 million per month in return for the name lending to Nonindicted 5 with Defendant 1’s approval.

B. In light of the following circumstances, the process of registering the representative of Nonindicted Co. 2 and Nonindicted Co. 3, which can be acknowledged by the above evidence, (i) through (viii) can be sufficiently recognized that the instant transaction is a disguised processing transaction recorded falsely in the aggregate table of tax invoices by seller for the purpose of having Nonindicted Co. 1 deduct the input tax amount or refund the value-added tax, and furthermore, Nonindicted Co. 2 and Nonindicted Co. 3 appear to be a wide-scale coal business established for the purpose of having Nonindicted Co. 1 deduct the input tax amount and discontinue the business without paying the value-added tax.

① In the absence of legal intent, Defendant 1 appears to have not been required to establish and operate the company by borrowing the name from a third party even when paying monetary consideration, and the said Defendant did not explain the reason for the borrowed name during the trial of this case.

② The nominal representatives of Nonindicted Company 2 and Nonindicted Company 3 did not participate in all the company’s operation at all, and each of the above companies was the same as Nonindicted Company 1 and the computer IP addresses and telephone numbers, and the fact that the aforementioned companies are closed ex officio by the tax office on September 2010, before and after the instant crime, due to the delinquency in value-added tax.

③ Defendant 1 denied the facts charged in this court. However, at the time of the second examination of the suspect, the second examination of the suspect: “The above Defendant established Nonindicted Company 2 and 3 under the name of another person; and in fact, managed and operated all of the facts at Nonindicted Company 1. Transactions between Nonindicted Company 1 and 3 and Nonindicted Company 2 are consistent with the facts charged; and (ⅰ) the above Defendant established and operated only Nonindicted Company 1, and was not involved in the process of establishment and operation of Nonindicted Company 2 and Nonindicted Company 3; Nonindicted Company 1 was properly supplied with human resources from Nonindicted Company 3 and supplied them to Nonindicted Company 1; (iii) the Defendant did not appear to have been aware of the facts charged at the time of the investigation; and (iv) the Defendant did not appear to have been aware that there was no objective confession or operation of the instant investigation by the Defendant, including the loan from a third party; and (iv) the Defendant did not appear to have been present at the time of the investigation, and there was no objective confession or operation of the instant company.”

④ On December 27, 2010, when the investigation into Pyeongtaek-si Office had started, Defendant 2 instructed Nonindicted Company 8 to appear, “If it was difficult to help Nonindicted Company 2 and it was not a cost for lending an identification card in connection with the establishment of Nonindicted Company 2, it was not a cost for the establishment of the said company.” Defendant 3 found Nonindicted Company 5 several times at the Yeongdeungpo-gu Office, and instructed Nonindicted Company 1 to the effect that “The Party was actually managing the Nonindicted Company 3, but it was in charge of the management work at Nonindicted Company 1; Defendant 1 and Nonindicted Company 1 were in charge of manpower recruitment; Defendant 3 and Nonindicted Company 1 were to be present at the Prosecutor’s office on June 16, 201; Defendant 1 and Nonindicted Company 3 were to be present at the same time, and Defendant 5 were to be present at the prosecution’s office on July 15, 201, and Defendant 1’s statement to the same effect as the Defendant 5’s statement at this case.”

⑤ Defendant 1 explained to the effect that, in the absence of any special reason to separately establish Nonindicted Company 2 and Nonindicted Company 3 other than Nonindicted Company 1, there is no provision prohibiting the supply of 50 or more human resources from a single human resources supplier under the internal regulations of Bosung Information and Communications, and that, in light of the fact that the above Defendant’s defense counsel was examined on May 1, 200, the management of human resources became difficult due to the rapid increase in the number of business partners of Nonindicted Company 1, the business partners separately establish Nonindicted Company 2, Nonindicted Company 3, and Nonindicted Company 1, Nonindicted Company 1, Nonindicted Company 2, and Nonindicted Company 3, to the effect that the supply of human resources by a single human resources supplier, and that it is difficult to separately inform the aforementioned Defendant of the reason that it is difficult for the Defendant to separately supply human resources to be in charge of providing human resources to the said Nonindicted Company 2 and Nonindicted Company 3, and that it is difficult for the Defendant to separately inform him of the reason that it is difficult for the aforementioned Defendant to separately supply human resources to the above corporation.

6) Defendant 1 did not directly dispatch a worker to Nonindicted Company 2 and Nonindicted Company 3, etc., and even without providing any explanation on the reason that it is necessary for Nonindicted Company 1 to undergo the work of Nonindicted Company 1 (the business operated by Nonindicted Company 1, Nonindicted Company 2, and Nonindicted Company 3 is deemed to be a temporary work agency under the Act on the Protection, etc. of Temporary Agency Workers (hereinafter “the Workers Dispatch Act”). According to Article 5(1) of the Workers Dispatch Act and Article 2(1) of the Enforcement Decree of the same Act, the business is limited to the business subject to temporary placement [attached Form], and the temporary work agency is excluded from the business subject to temporary placement. However, if Nonindicted Company 2 and Nonindicted Company 3 dispatch a worker to Nonindicted Company 1, who is engaged in temporary work agency business, and if Nonindicted Company 1 re-sects it to its business partners, it is also in violation of the above Act because it is not a business that permits temporary placement of workers under the Workers Dispatch Act).

7) On May 11, 2010, Nonindicted Co. 1 was faced with financial difficulties before and after the instant case, such as receiving disposition on default on the grounds of the unpaid amount of tax equivalent to KRW 148,356,790, in total from Pyeongtaek 148,356,790. The financial crisis of Nonindicted Co. 1 appears to have been the motive for the instant crime.

8. Nonindicted Company 2 and Nonindicted Company 3’s account (Account Number 1 omitted) in the name of Nonindicted Company 3: A business bank (Account Number 1 omitted), Nonindicted Company 3: A business bank (Account Number 2 omitted); Defendant 1 did not provide any reasonable explanation on the reasons therefor.

○ Imprisonment: one month - four years and six months;

○ Fines

50,000 won - Note 10) 255,381,943

50,000 won - Note 11) 460,180,525 won

50,000 won - Note 12) 364,036,196

2. Determination of sentence;

In light of the fact that Defendant 1’s total supply value of the aggregate of the aggregate tax invoices by seller submitted to the tax office with false entry amounts to approximately KRW 3.5 billion, which leads to the risk of loss of tax revenue equivalent to approximately KRW 3.50 million, which corresponds to 10 million of the above supply value, and that the above Defendant committed an intelligent and organized crime by ordering the above Defendant to establish a company with limited carbon under a third party’s name, and that it appears that the above Defendant instructed the nominal lender to make a false statement through the above Defendant even in the course of investigation, the crime of this case is very poor, and the circumstances after the crime are not good, so it is necessary to punish the above Defendant with strict punishment.

However, considering the following as a whole: (a) the above defendant has no criminal record or heavier than that of the same criminal record or suspended sentence; (b) the above defendant appears to have been in room of improvement and edification as a senior citizen of society; and (c) the execution of detention in prison with respect to a fine to be imposed concurrently imposed in light of his/her own ability is likely to be carried out; and (d) the above defendant’s age, character, conduct, family relationship, environment, occupation, etc. and all of the sentencing conditions revealed in the trial process and the trial process of this case including the above defendant’s age, character and behavior, family relation, occupation, etc., as a whole, the term of imprisonment and the amount of fine (the first crime 30,00,000 won + the amount of 2 crime 50,000,000 won +

With respect to the criminal facts in the judgment, the prosecutor, on the ground that the defendant was "for profit-making purposes" and that the total value of false entries constitutes between three billion won and five billion won, each act in the judgment shall be deemed a blanket crime, and charged for the application of Article 8-2 (1) 2 and (2) of the Act on the Aggravated Punishment, etc. of Specific Crimes (hereinafter "Special Crimes Act").

2. Determination

A. “Profit-making purpose” stipulated in Article 8-2(1) of the Special Act refers to acquiring economic benefits (see, e.g., Supreme Court Decisions 2009Do13342, Feb. 11, 2010; 2010Do7289, Nov. 11, 2010); and Article 10(3)3 of the Punishment of Tax Evaders Act provides that the act of submitting a false list of total tax invoices by seller is almost for the purpose of deducting input tax or refunding value-added tax (hereinafter “the purpose of tax evasion”). In light of the above special circumstances, the purpose of Article 10(3)3 of the Punishment of Tax Evaders Act is to interpret that the aforementioned special purpose of tax evasion is to include “for profit-making purpose” as well as that of Article 10(1)3 of the Punishment of Tax Evaders Act, and thus, the act of submitting a list of total tax invoices by seller is not only an indirect method of tax evasion, but also an indirect method of tax evasion with the requirement of Article 10(2).

B. Based on the above legal principles, as seen earlier, the Defendant committed each act with the intention of evading taxes for Nonindicted Company 1. However, there is no evidence to prove that the Defendant had any other direct or indirect economic benefit, and thus, it cannot be deemed that there was “for profit” at the time of each act committed by the Defendant.

C. Therefore, this part of the facts charged does not have any proof of the excessive subjective elements of the crime, and thus, the acquittal should be pronounced pursuant to the latter part of Article 325 of the Criminal Procedure Act. However, as long as the court found the defendant guilty of the violation of the Punishment of Tax Evaders Act in a single relationship with the above facts charged, it shall not be

In collusion with the above defendants, the above defendants prepared and submitted a list of total tax invoices by seller for profit in collusion with the above defendants.

2. Determination

A. The facts charged in this case against the above Defendants are crimes falling under Article 8-2 (1) 1 of the Aggravated Punishment Act, Article 10 (3) 3 of the former Punishment of Tax Evaders Act, and Article 30 of the Criminal Act. In light of the following ① or ④, it constitutes an offense subject to prosecution upon which a tax official, etc. may institute a public prosecution only upon a complaint.

① Article 21 of the former Punishment of Tax Evaders Act provides that "No prosecutor may institute a public prosecution against an offense under this Act unless the Commissioner of the National Tax Service, the commissioner of a regional tax office, or the head of a tax office files an accusation." Article 8-2 (1) of the former Punishment of Tax Evaders Act provides that "The purpose of "in addition to the elements of Article 10 (3) of the former Punishment of Tax Evaders Act," and "the sum of the amounts of supply" is at least three billion won, and there is a difference in the elements of the crime. However, both crimes are to punish the issuance of false tax invoices, etc., and the protection of the legal interest is the same for punishing both crimes, and the crime of violation of Article 8-2 (1) of the former Punishment of Tax Evaders Act is to punish a case where the purpose of profit-making is among the acts under Article 10 (3) of the former Punishment of Tax Evaders Act,

② Article 16 of the Aggravated Punishment Act provides that a public prosecution against a crime under Article 6 or 8 of the Aggravated Punishment Act may be instituted in the absence of a complaint or accusation. In principle, in the former Punishment of Tax Offenses Act, a public prosecution against a tax offense is a crime subject to victim's complaint, which requires a public prosecution against a tax official, and a special provision which requires a part of the offense to be a crime subject to victim's complaint under the Aggravated Punishment Act is adopted. Article 16 of the Aggravated Punishment Act provides that only a crime under Article 6 or 8 of the Aggravated Punishment Act is an offense subject to victim's complaint, but the crime under Article 8-2 (1) of the Aggravated

③ Article 9(4) of the former Procedure for the Punishment of Tax Evaders Act (amended by Act No. 11132, Dec. 31, 2011) provides that “The Commissioner of the National Tax Service, the Commissioner of the Regional Tax Office, or the head of the Regional Tax Office or the head of the Regional Tax Office shall immediately file a complaint against a tax official in cases where the penalty is deemed to be imprisonment in consideration of the offense committed under the Punishment of Tax Evaders Act. This provision provides for the tax official’s obligation to file a complaint only in cases where the offense committed under the Punishment of Tax Evaders Act is deemed to be punishable by a crime subject to victim’s complaint, but it does not constitute an offense subject to victim’s complaint under the above provision, and thus, it is difficult to interpret that the tax official’

④ Article 5-7 of the former Aggravated Punishment Act (amended by Act No. 4702 of Jan. 5, 1994) provides for punishing “a person who commits or attempts to commit a crime under Article 297 or 298 of the Criminal Act by carrying a deadly weapon or other dangerous object or jointly with two or more persons, or a person who commits a crime and a bodily injury resulting from such crime,” and Article 5-7 of the former Aggravated Punishment Act (amended by Act No. 4702 of Jan. 5, 1994). Article 5-7 of the former Aggravated Punishment Act provides for “a person who commits a crime under Article 297 or 298 of the Criminal Act, or who commits a crime under Article 10(3) and the former part of Article 4 of the Punishment of Tax Evaders Act, which is an offense subject to victim’s complaint, and Article 8-2(1) of the Aggravated Punishment Act, which is an offense subject to victim’s complaint, shall be further added to the elements of a crime subject to complaint.

B. However, even upon examining the record, there is no evidence to acknowledge that there was a tax official's accusation against the above Defendants (if there is a tax official's accusation against the above Defendants, but Article 233 of the Criminal Procedure Act, which provides for the subjective indivisible principle of complaint against a crime subject to victim's complaint, does not apply mutatis mutandis to a tax official's accusation (see, e.g., Supreme Court Decision 2004Do4066, Sept. 24, 2004). Thus, it cannot be deemed that the effect of accusation against the above Defendants extends to the above Defendants).

C. Therefore, since the prosecution of this case against the above Defendants is null and void in violation of the provisions of the law, each of them is dismissed in accordance with Article 327 subparagraph 2 of the Criminal Procedure Act.

It is so decided as per Disposition for the above reasons.

[Attachment Form 7]

Judges Kim Jin-jin (Presiding Judge)

1) The above Defendant and his defense counsel also argued that Nonindicted Company 2 and Nonindicted Company 3 were not so-called “pester” (the issue of this case was the defense counsel). This appears to the purport that, without the purpose of actually running the business, Nonindicted Company 2 and Nonindicted Company 3 did not constitute so-called “explosion business” established for the purpose of getting Nonindicted Company 1 deducts input tax amount or refund value-added tax without paying value-added tax. However, even if Nonindicted Company 2 and Nonindicted Company 3 were not a large coal business, if the Defendant prepared and submitted a false list of tax invoices by individual purchaser as if there was no actual transaction between Nonindicted Company 1 and Nonindicted Company 2 and Nonindicted Company 3, even though it was not a large coal business, it constitutes the element of Article 10(3)3 of the former Punishment of Tax Evaders Act, and the Defendant and his defense counsel’s assertion is merely an assertion on the grounds for sentencing, not an assertion that the above crime constitutes the element of a crime.

2) Nonindicted 12 and Defendant 2’s white part in the private village of Nonindicted 8 are married to Nonindicted 13.

Note 3) 1016, 1017 pages of investigation records

Note 4) 13,103 pages of investigation records

Note 5) Investigative records 1003 et al.

Note6) Defendant 3: Not more than 994 pages of investigation records, Defendant 2: Not more than 1025 pages and not more than 1058 pages of investigation records

7) The credibility of a confession made by a defendant at the prosecution cannot be said to be doubtful solely on the grounds that the confession is different from the legal statement or that it is excessively unfavorable to the defendant. The credibility of a confession should be determined by comprehensively taking into account the following: (a) whether the content of the confession itself is objectively rational; (b) the motive or reason of the confession; (c) what is the motive or reason of the confession; and (d) what is the circumstance leading up to the confession, and whether there is any conflict or inconsistency with the confession among circumstantial evidence other than the confession (see, e.g., Supreme Court Decision 2012Do571, May 2

Note 8) Investigative records no more than 595 pages

Note 9) Investigative records 694 pages

10) 851,273,145 won x value-added tax rate 10% x 3 times, and servers (hereinafter the same shall apply)

Note 11) 1,53,935,086 x value-added tax rate 10% x 3 times

Note 12) 1,213,453,98 won x value-added tax rate 10% x 3 times