The plaintiff's claim is dismissed.

Litigation costs shall be borne by the plaintiff.

1. Basic facts

A. 1) The Plaintiff is a corporation that was established on June 18, 2015 and runs the business of wholesale and retail of non-ferrous metals in Daegu Dong-gu building and C from around that time. 2) D is an individual entrepreneur who runs the business of wholesale and retail in the name of “F” in Gwangju City from January 14, 2015 to May 31, 2016.

B. D’s return of value-added tax and Plaintiff’s payment of value-added tax 1) filed a value-added tax return as described below [Attachment 1] in the period of value-added tax for the first period from 1 to 1, 2016 [Attachment 1] applicable to D’s return of value-added tax (unit: unit) 618,312, 139, 687, 689, 581, 582, 652, 910 4, 208, 654, 630, 819, 22, 498, 792, 907, 339, 439, 437, 538, 198, 281, 205, 2015, 206 of the former Restriction of Special Taxation Act (amended by Act No. 10635, Jan. 1, 2015).

However, Article 106-9 of the amended provisions under the above Act shall take effect from October 1, 2016 pursuant to the proviso to Article 1 of the Addenda of Act No. 13560.

Therefore, Article 106-9 of the Restriction of Special Taxation Act prior to the amendment is applied to the value-added tax for the first period of 2016.

Article 106-9 (hereinafter referred to as the "Special Provisions of this case") paid the total value-added tax of KRW 3,062,076,133 pursuant to Article 106-9 (3).

C. The Director of the Central District Tax Office of the Resolution of Correction of Value-Added Tax for D is related to each purchase transaction and sales transaction listed above [Do Table 1] as a result of the tax investigation for D.