The appeal is dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined.

1. As to the grounds of appeal Nos. 1 and 3, Article 11(1)2 of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013; hereinafter the same) provides that the zero tax rate shall apply to the supply of “services provided overseas.”

And it is not whether the other party to whom the service is supplied is a domestic corporation or a foreign corporation or a domestic place of business of a foreign corporation.

Therefore, the other party who received services from the Plaintiff constitutes a domestic corporation.

Even if a permanent establishment exists in Korea or is a foreign corporation, the allegation in the grounds of appeal that there is an error of mistake of facts or misapprehension of legal principles in the judgment of the court below that deemed otherwise cannot be accepted without further review.

2. Regarding ground of appeal No. 2

A. Article 10(2)1 of the former Value-Added Tax Act defines the place where the service is supplied as “the place where the service is provided or the goods, facilities, or rights are used.” Thus, whether the transaction is subject to zero-rate tax should be determined based on the place where the service is provided. If the important and essential parts of a single service provided by a domestic corporation are performed overseas, the place where the service is provided shall be deemed overseas even if a part

(See Supreme Court Decision 2004Du7528, 7535 Decided June 16, 2006, etc.). B.

The court below held that ① a corporation incorporated pursuant to the Singapore Act (C; hereinafter “C”) was engaged in the business of purchasing and recovering overseas convertible bonds issued by Korean listed companies (hereinafter “CS bonds”) from the Hong Kong branch of the Hong Kong branch of the Hong Kong Bank of 2009 (CS, hereinafter “CS”), and ② the Plaintiff, a domestic corporation, has acquired CSS bonds with C in the process.