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

The reasoning of the judgment of this court is as follows: (a) the reasoning of the judgment of the court of first instance is the same as that of the judgment of the court of first instance, and thus, (b) pursuant to Article 8(2) of the Administrative Litigation Act

2. Additional determination

A. The Plaintiff asserted that the Plaintiff is exempt from value-added tax even between the BB and the Plaintiff, as the Plaintiff provided the immediately education services to the students, and the Plaintiff takes charge of only the role of the individual in the middle.

The terms of contract between the Plaintiff and the BB corporation indicated in the evidence No. 4, and the Plaintiff are different from the Plaintiff’s appearance and sentences, 1:1 telephone class, hearing and problem pool, 1:1 and writing writing, etc., and the amount and calculation method of the Plaintiff’s service costs and tuition fees paid to the Plaintiff to the BB corporation. In light of the Plaintiff’s contents and methods of providing the Plaintiff’s service, and the motive for the students to select the Plaintiff’s educational service, it is difficult to view that the Plaintiff’s service provision of the BB corporation is carrying out only the formal role of simply delivering the Plaintiff’s service to the students. Accordingly, the other party to the service cannot be deemed as the Plaintiff’s student, and the value-added tax is exempted at the stage of directly providing the education service to the students, and thus, the provision of the service to the Plaintiff of the BB corporation cannot be deemed as exempt.

The cases of providing educational services through school juristic persons, enterprises, government agencies, etc. invoked by the Plaintiff are related to factual relations in which a business operator can be deemed to have provided educational services directly to students, etc., since the status of school juristic persons, etc. which entered into a contract with a business operator providing services is formally a form. Therefore, this case cannot be deemed the same

Furthermore, our former Value-Added Tax Act requires the government's permission or authorization as a condition of tax exemption for educational services, and the laws and regulations of the Philippines also recognize the tax exemption for educational services subject to the authorization of the Ministry of Education, Culture and Tourism or the Higher Education Committee in the case of private educational institutions. In addition to the registration of the Securities and Exchange Commission for the purpose of acquiring legal personality, unless there is no evidence to acknowledge that the BB corporation has obtained the authorization of the Ministry of Education, Culture and Tourism or higher Education Committee or the authorization of the Republic of the Philippines government equivalent thereto, it can not be deemed that the

Ultimately, the plaintiff's above assertion is without merit.

B. The Plaintiff asserts that the instant disposition contravenes the principle of non-discrimination under tax treaties between Korea and the Philippines.

However, the above argument is based on the premise that the domestic corporation provides the Plaintiff with the instant telephone fishing service, and in light of the above, even if the domestic corporation provides the Plaintiff with the instant telephone fishing service, it cannot be viewed as eligible for tax exemption, and the above argument cannot be accepted.

C. The Plaintiff asserts that, prior to the instant disposition, a non-taxable practice was established regarding the same matter as in the instant case, the instant disposition is unlawful against the non-taxable practice and the principle of non-taxation.

However, in light of the respective descriptions in Eul evidence Nos. 5 through 8, 14 through 17, 20, 21, 22, and 24 (including paper numbers) alone are insufficient to recognize that the non-taxable practice on the same matter as in this case has been established, and there is no other evidence to acknowledge it (in particular, it is difficult to deem that the non-taxable practice has been established at the time of the establishment of the liability for tax payment of the first-year value-added tax in 2009). The plaintiff's above assertion is without merit.

3. Conclusion

The judgment of the first instance is justifiable. The plaintiff's appeal is dismissed.