The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. Article 9(2) of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013) provides “when a service is provided” as the time of supply for the service. Article 22 of the former Enforcement Decree of the Value-Added Tax Act (wholly amended by Presidential Decree No. 24638, Jun. 28, 2013) upon delegation under paragraph (4) of the same Article provides that “In the case of ordinary supply, when the provision of service is completed” (Article 1) shall be determined as the time of supply for the specific service.

The term "when the provision of service is completed" refers to the time when a person provided with service can use the computation of the provision of service by taking into account the scope of the provision of service under a contract between a trader and the terms and conditions of a contract, that is, the time when a person provided with service can use the computation of the provision of service by taking into account the scope of the provision of

(2) On August 21, 2008, the lower court held that: (a) the Plaintiff completed the installation of solar power generation facilities from October 5, 2009 to January 4, 2010 to conclude a contract for the construction of solar power generation facilities with A and the construction cost of KRW 4.3 billion (excluding value added tax) on October 22, 2009; (b) the Plaintiff acquired the instant power generation facilities on January 4, 2010; and (c) on January 6, 2010, issued a certificate of pre-use inspection and a certificate of inspection of electrical facilities on January 6, 2010 to the Korea Electrical Safety Corporation; and (d) the Plaintiff provided the service of KRW 300,000,000,000,000 for the total construction cost of the instant construction project; and (e) the Plaintiff provided the service of KRW 300,000,000,000,000.