A. The Plaintiff is a company established in August 199 for the purpose of research and dissemination of the early middle and high-level certified learning areas.

B. From around 2010 to 2014, the Plaintiff entered into an agreement on the operation of the Gifted Education Center (hereinafter “instant operating agreement”) with its franchisees.

From the franchisees who entered into a contract from around 2010 to 2011, the Plaintiff received KRW 4 million each year from the franchisees who entered into the contract, KRW 2 million each year, KRW 5 million each year from the franchisees who entered into the contract from around 2012 to 2014, and KRW 3 million each year from the franchisees who entered into the contract, as “expenses for the conclusion of the contract”

(hereinafter “instant issues amount”) C.

The Plaintiff reported value-added tax to the Defendant from January 2010 to February 2014, and reported the instant key amount as sales exempt from value-added tax on the ground that it constitutes “value-added tax” under Article 26(1)8 of the Value-Added Tax Act [Article 12(1)8 of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013)].

On July 2, 2015, the Defendant deemed that “the issues of this case are “franchises paid in return for receiving gifted education operating rights, trade names and trademark rights, education for teachers, know-how of educational programs, etc.,” and deemed that it constitutes subject to value-added tax.” On July 2, 2015, the Defendant issued a notice to the Plaintiff on January 46, 2010, KRW 56,109,580, KRW 46,109,580, KRW 61,60,160,80, KRW 61,70, KRW 47,017, KRW 49,659, KRW 460, KRW 37,59, KRW 980, KRW 2013, KRW 549, KRW 205, KRW 2015, KRW 2014, KRW 204, KRW 25460, KRW 2045, KRW 2015, KRW 2514, KRW 25461465.

(hereinafter “Disposition in this case”). 【No dispute exists, Gap 1, 4, and 5 evidence, Eul 1 evidence, and the purport of the whole pleadings

2. The details of the relevant Acts and subordinate statutes are as shown in attached statutes;

3. Whether the instant disposition is lawful