1. The Defendant’s value-added tax of KRW 93,060,710 (including additional tax) in 2010, as the Plaintiff on January 7, 2015.

1. Details of the disposition;

A. The Plaintiff (formerly changed: Il Tricom Co., Ltd.) is a corporation established on January 16, 2008 and engaged in advertisement production and agency business.

나. 원고는 주식회사 이피피휴먼네트웍스가 2007. 7. 18. 서울메트로와 체결한, 서울지하철 1, 3, 4호선 각 역사 및 종합관제센터에 열차정보안내시스템(이하 ‘이 사건 시설물’이라 한다)을 제작ㆍ설치하여 2023. 7. 17.(15년, 다만 시설공사기간 1년이 추가됨)까지 사용수익하고, 그 대가로 200억 원(부가가치세 별도, 이하 ‘이 사건 광고료’라 한다)을 지급하는 외에 계약기간 만료 시 이 사건 시설물의 소유권을 무상으로 서울메트로에 이전하는 계약(이하 ‘이 사건 계약’이라 한다)을 2008. 3. 31. 승계하였다.

C. The Seoul Qart issued the following tax invoices (hereinafter “instant tax invoice”) from the first to the first period of 2010, with the value of supply calculated in proportion to the acquisition value of the instant facilities during each taxable period during the contract period, from the date of the first to the first period of 2012. The Plaintiff was exempted from the input tax amount of value-added tax in accordance with the said tax invoice issued by the Seoul Qart.

However, on October 18, 2012, the amount of value-added tax base calculated on October 18, 2012 ought to be based on the “market price at the time the ownership is transferred” rather than on the “acquisition value” of the instant facilities. On July 2023, where the ownership of the instant facilities is transferred without compensation, the market price of the instant facilities is zero won in view of the lifespan (5 to 10 years). As to the instant tax invoice issued by the Plaintiff from January 1, 2010 to 1, 2012, the revised tax invoice of this case (hereinafter “the revised tax invoice”).

A. The issue was made.

E. The Defendant issued the revised tax invoice of this case as above.