1. On July 9, 2014, the Defendant imposed a value-added tax of KRW 46,667,386 on the Plaintiff in 2012.

1. Details of the disposition;

A. On July 23, 2012, the Plaintiff: (a) received 22 copies of purchase tax invoices of KRW 267,037,00 from “C” and filed a return on the second half-year value added tax in 2012 from the output tax amount; (b) deducted the relevant input tax amount of KRW 26,703,70 from the output tax amount; and (c) filed a return on the second half-year value added tax in 2012.

B. From July 4, 2013 to September 24, 2013, the Director of the Daejeon Regional Tax Office conducted a tax invoice tracking investigation with respect to C, and confirmed that the purchase tax invoice issued by C to the Plaintiff is a false tax invoice without real transactions and notified the Defendant thereof.

C. On July 9, 2014, the Defendant issued a revised notice of KRW 46,667,386 (including additional taxes) on the ground that the Plaintiff did not deduct the relevant input tax amount on the ground that “the Plaintiff received the purchase tax invoice without being provided with services from C,” and that it did not notify the Plaintiff of the amount of value-added tax 46,

(hereinafter “instant disposition”) D.

On October 7, 2014, the Plaintiff filed an objection with the Director of the Daejeon Regional Tax Office against the instant disposition, but the said objection was dismissed on November 14, 2014. On February 16, 2015, the Plaintiff filed an appeal with the Director of the Tax Tribunal for adjudication on February 16, 2015, but the said appeal was dismissed on October 7, 2015.

[Grounds for recognition] Evidence No. 1-1 and No. 2, and the purport of the whole pleading

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion is limited to a person who lends his/her business registration name while running human resources supply business in the name of D, “B,” and the management of all business and funds related to human resources supply business in B has been carried out directly by D.

Nevertheless, the instant disposition imposing value-added tax on the Plaintiff, who is only the nominal lender, is unlawful as it goes against the principle of substantial taxation.

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

C. Determination of Article 14(1) of the Framework Act on National Taxes is the income, profit, property, act or transaction subject to taxation.