All appeals are dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined.

1. Article 13(4) of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013) provides that the tax base of value-added tax on the import of goods shall be the aggregate of the dutiable value of customs duties, customs duties, individual consumption tax, liquor tax, education tax, special tax for rural development, and traffic, energy and environment tax (Article 13(4) of the former Value-Added Tax Act prior to the amendment by Act No. 8142, Dec. 30, 2006; Article 13(4) of the former Value-Added Tax Act prior to the amendment by Act No. 8826, Dec. 31, 2007; Article 30 of the former Customs Act (wholly amended by Act No. 10424, Dec. 30, 2010) provides that “The dutiable value of imported goods shall be included in the main sentence of Article 30(1) of the former Value-Added Tax Act, including the amount actually paid by a seller for the following transaction price:

In addition, Article 20(6) of the former Enforcement Decree of the Customs Act (amended by Presidential Decree No. 22816, Apr. 1, 2011) provides that “other indirect payments” under the main sentence of Article 30(2) of the Act shall include the following amounts: Provided, That where a third party pays all or part of the price of imported goods at the request of a seller, the amount of payment refers to:

On the other hand, Article I of Annex I to the Agreement on Implementation of Article VII of the General Agreement on Tariffs and Trade 1994.