부가가치세부과처분취소
1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
Purport of claim and appeal
The first instance court.
The reasoning of the judgment of the court of first instance is as follows, with the exception of adding or adding some of the reasons for the judgment of the court of first instance, and adding the judgment in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.
The following shall be added to 5 pages 3:
【 even if SCB, etc. performed the business of preparing reports or preparing guidelines in a foreign country, which is the location thereof, by analyzing the trend, it is meaningful that the content of the consultation is delivered to the Plaintiff through e-mail, etc. and the Plaintiff can confirm it and utilize it in the business place. Thus, even if SCB, etc. performed part of the service abroad, it is difficult to deem that the essential part of the service of this case was carried out overseas. The following is added between 5 pages 3 and 4, and the four parallels “B” are added to “III.”
(2) The service of this case may be provided by the plaintiff with information or data on the management status of the plaintiff. The substantial part is that the person in charge of SCB, etc., directly visited the plaintiff's domestic business place and provided services suitable for the situation through face-to-face meeting, etc., and after having asked questions about the management, the plaintiff used it to receive an answer. Thus, it constitutes an important part of the service of this case where the plaintiff sent e-mail to SCB, etc., or sent e-mail to telephone with the plaintiff's domestic business place or received telephone with the plaintiff's domestic business place, or where the person in charge of SCB, etc. directly visited the domestic business place and visited the domestic business place to identify the facts in
④ As above, the former Value-Added Tax Act adopts the taxation principle for consumption.