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 the same as the ground for the judgment of the court of first instance, except for the part to be determined additionally in the following paragraphs, and thus, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of

The plaintiff asserts that value-added tax is exempted even between the Switzerland corporation and the plaintiff, since the Switzerland corporation provided the right education services to the students, and the plaintiff takes charge of the role of the individual in the middle.

In light of the content and method of calculating the amount of service costs and tuition fees paid by the Plaintiff to the corporation of the Philippines, and the motive for the students to select the Plaintiff’s educational services, it is difficult to view that only the above telephone class is separately removed, and it is only the formal role of the Plaintiff simply delivering the services provided by the corporation of the Philippines to the students. In light of the content and method of the Plaintiff’s provision of services and the motive for the students to select the Plaintiff’s educational services, it is difficult to view that the Plaintiff is performing the formal role of delivering the said services to the students.

Therefore, the other party to the service provided by a corporation in the Philippines cannot be deemed as the Plaintiff’s student, and since the service provider is exempt from value-added tax at the stage of directly providing educational services to the students, the provision of services to the Plaintiff cannot be deemed as a tax-free object.

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, we are the Gu.