A. A Co., Ltd. (hereinafter “A”) concluded a contract on July 21, 2010 between the Plaintiff and the Plaintiff to transfer to the Plaintiff any claim related to the national tax refund that A would be entitled to refund according to the said final return, in advance of the final return of value-added tax for the first term of January 2010.

B. On July 21, 2010, A filed a final return on the sales tax amount of KRW 0,925,90,000, and KRW 925,900,000 for the first term portion of value-added tax in 2010 with the head of the competent tax office affiliated with the Defendant, and on the same day, A notified the Defendant of the assignment of claims with a fixed date, and submitted to the head of the competent tax office a written request for the transfer of national tax refund relating to KRW 925,90,000 for the said tax refund amount.

C. The head of the Suwon Tax Office did not pay the national tax refund to the Plaintiff even if a request for transfer was made by A, on February 8, 2011, the Plaintiff notified the head of the Suwon Tax Office of the results of the determination of the national tax refund and requested a request to the Plaintiff. On February 17, 2011, the head of the Suwon Tax Office notified the Plaintiff of the results of the tax investigation on the value-added tax for the first period of January 2010, that the notified amount would not have any tax refund to the Plaintiff.

The head of the Suwon Tax Office, on March 3, 2011, received the value-added tax for the first period of 2010 by A on March 3, 2011, on the basis that the amount equivalent to the purchase tax invoice (supply price: -5,873,878,963) that A should have received should be deducted from the input tax amount, should be deducted from the input tax amount, and that the total amount of KRW 931,90,000 that A reported as the input tax amount should be added to the amount of KRW 6,00,000 that was reported at the time of the preliminary return of the first taxable value-added tax in 200 and the input tax amount of KRW 925,90,00 that was reported at the time of the final return.

Among them, 587,387,897 won is not recognized as input tax amount, and tax invoices shall be calculated as 344,512,103 won [(931,90,000 won - 587,387,897 won)] for the principal tax of value-added tax for the first term of 2010, and tax invoices shall be processed, discarded, and issued.