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.

1. This court's explanation concerning this part of the circumstances of the disposition is the same as the part of the second to third to fourth, 5 to 14 in the corresponding part of the judgment of the court of first instance, except for the case where "237.943,250 won" in the second to third to 237,943,250 won in the judgment of the court of first instance is "237,943,250 won" in Article 13 of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the instant disposition is lawful

A. HTS (HTS) is designed to secure the collection of loans that the Plaintiff’s assertion B allows the customer to use to the customer, and is merely a tool that delivers the customer’s order to the HTS to the securities company.

Therefore, the principal service provided by the Plaintiff is not a lending of transaction account and a provision of transaction system, but a lending of money. Therefore, this constitutes a service exempt from value-added tax.

Even if the Plaintiff’s service constitutes an investment brokerage business and did not obtain authorization under the Capital Markets Act, imposing taxes other than administrative regulations based on unmanned prices would be double punishment, as well as go against the tax practice previously maintained, and may cause serious equity in taxation.

(b) as shown in the attached Form of the relevant statutes;

C. The reasoning for this court’s explanation concerning this part of the facts of recognition is the same as that of the 3rd court’s 24th to 16th court’s 4th e.g., Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

Judgment

1) The term "investment brokerage business" means the business of selling and purchasing financial investment instruments, soliciting offers, offering, and accepting offers for such instruments, or soliciting offers, offering, and accepting offers for the issuance and acceptance of securities on another person's account, regardless of in whose name the contract is held.

(Article 6(3) and (3) of the Capital Markets Act are explicitly added to the "trade".