The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. As to the ground of appeal No. 1, Article 30(1) of the former Customs Act (amended by Act No. 10424, Dec. 30, 2010; hereinafter the same) provides that “The dutiable value of imported goods shall be the transaction price adjusted by adding the following amounts to the price actually paid or payable by the buyer for the goods sold for export to Korea.” Accordingly, the main sentence of subparagraph 1 provides that “the commission and brokerage fee to be borne by the buyer” as one of the customs values of imported goods and excludes “purchase commission” in the proviso.

(2) citing the reasoning of the judgment of the court of first instance, the court below acknowledged the following facts: (a) the Plaintiff was a subsidiary in the Republic of Korea of the Regional Robbba Swear Co., Ltd. (hereinafter “U.S. head office”) located in the United States; (b) the Plaintiff imported the clothing, shoes, and bags with a trademark of the local forum 59 times from April 1, 2008 to December 31, 2009 (hereinafter “instant imported goods”); and (c) filed an import declaration without adding the Plaintiff’s customs duties and value-added tax to its dutiable value, etc. on March 29, 2013 and on May 9, 2013.

The next court below held that ① the operation of the headquarters of the United States is conducted through product planning, identification of the foreign supplier, negotiation of favorable terms and conditions with the foreign supplier, determination of the cost of the product, and phishing, etc.; ② the head office of the United States provides the above phishing services under the service contract entered into with the Plaintiff, and receives the cost of the above phishing services, including the Plaintiff.