1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. The reasoning for the court’s explanation as to the instant case is as stated in the reasoning of the judgment of the first instance, except for the addition of the determination of a new argument made by the Defendant in the trial under Paragraph (2) below, and thus, it is consistent with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

2. Additional determination

A. The Defendant’s assertion 1) According to the “satisfy and comprehensive table (No. 6)” attached to the instant contract for a business agency agreement under the instant primary contract, the Plaintiff’s provision of services to the dalgorithm pursuant to the said contract (hereinafter “instant service”).

(2) Article 22 Subparag. 2 of the former Enforcement Decree of the Value-Added Tax Act does not apply to the instant service. As such, Article 22 Subparag. 3 of the former Enforcement Decree of the Value-Added Tax Act applies to the service of this case, and Article 414,00,000 won, which the Plaintiff neglected to pay taxes, falls under the design management part at the first time of 201, and the supply price of the service is determined and determined and determined at the time of supply. (2) Even if the instant service constitutes “a continuous supply of any service that cannot be demarcated by its supply unit,” as prescribed by Article 22 Subparag. 2 of the former Enforcement Decree of the Value-Added Tax Act, the service of this case constitutes “10,000 won,” and the supply price of the service of this case reaches the first time of 200,000 won for each of “10,000 won for each of the above services.”

3. According to Article 40 of the Corporate Tax Act and Article 69(1) of the Enforcement Decree of the Corporate Tax Act, the ownership of profits and losses from the provision of services is subject to the work progress rate, i.e., the arbitrity rate.