The judgment below

Among them, the part on the imposition of value-added tax for the first and second period of 2012 is reversed, and this part is applicable.

The grounds of appeal are examined.

1. On the first and second imposition of value-added tax in 2012

A. According to Article 12(1)6 of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013) and Article 30 of the former Enforcement Decree of the Value-Added Tax Act (wholly amended by Presidential Decree No. 24359, Feb. 15, 2013) (hereinafter collectively referred to as “tax-exempt clause”), the supply of “educational services teaching knowledge, skills, etc. to students, etc. at schools, private teaching institutes, training institutes, teaching institutes or other nonprofit organizations permitted or authorized by, or registered with, or reported to, the competent authority, or reported to, the competent authority, or youth training facilities under the Juvenile Activity Promotion Act” is exempt from value-added

As such, the reason why the competent authority requires “permission, authorization, etc. by the competent authority” as a requirement for educational services subject to tax-exempt refers to a non-profit organization established with permission, authorization, etc. under the Act on the Establishment and Operation of Private Teaching Institutes and Private Teaching Institutes and other Organizations which set the standards for the specific facilities and equipment of schools and private teaching institutes, such as the Elementary and Secondary Education Act, the Higher Education Act, the Infant Care Act, the Early Childhood Education Act, the Act on the Establishment and Operation of Private Teaching Institutes and Extracurricular Lessons, the Installation and Utilization of Sports Facilities Act, and the Lifelong Education Act (hereinafter “Educational Facilities-related Act”), in full view of the fact that Article 30 of the Enforcement Decree of the above Act provides the “other non-profit organizations” concurrently with the private teaching institute teaching institutes and the teaching institutes.

(See Supreme Court Decision 2007Du23255 Decided June 12, 2008). However, Article 2 Subparag. 2 of the Lifelong Education Act not only provides “facilities corporations or organizations, the authorization of which is registered or reported under the Lifelong Education Act, but also provides other types of facilities.”