(a) the meaning and application requirements of the principle of good faith under Article 15 of the Framework Act on National Taxes;

B. Legislative intent of business registration under the Value-Added Tax Act, issuance of business registration certificate and legal nature of censorship

A. The principle of trust and good faith under Article 15 of the Framework Act on National Taxes refers to the fact that the interests of the other party who acted in trust shall not be infringed, and in general, in tax and legal relations, the requirements of the principle of trust and good faith should be applied to the acts of the tax authorities: first, the tax authorities should name the public opinion that is the object of taxpayer's trust; second, the tax authorities should not cause to the taxpayer for the reason that the name of the opinion of the tax authorities is justified; third, the taxpayer must trust the opinion and act in trust; fourth, the tax authorities should make a disposition contrary to the above opinion list, thereby infringing the taxpayer's interest; fourth, the disposition of the tax authorities shall be considered illegal.

B. In light of the provisions of Article 197-2 of the Income Tax Act, Article 5 of the Value-Added Tax Act, and Articles 7 through 9 of the Enforcement Decree of the Value-Added Tax Act, business registration under the Value-Added Tax Act intends to identify the taxpayer of the value-added tax and secure the taxation data. Thus, this is established by submitting a business report to the head of the competent district tax office as a simple business fact report, and the issuance of a business registration certificate is merely an act of issuing a certificate verifying such registration, and the censorship of the business registration certificate is also merely an act of proving the report of

(a) Article 15 (b) of the Framework Act on National Taxes; Article 197-2 of the Income Tax Act; Article 5 of the Value-Added Tax Act; Articles 7 through 9 of the Enforcement Decree

A. Supreme Court Decision 84Nu593 Decided April 23, 1985 and 84Nu593 Decided June 14, 1983; Supreme Court Decision 81Nu416 Decided July 26, 1983; Supreme Court Decision 83Nu228 Decided July 26, 1983

[Judgment of the court below]

Head of Eastern Tax Office

Daegu High Court Decision 86Gu153 delivered on January 21, 1987

The appeal is dismissed.

The costs of appeal are assessed against the plaintiff.

We examine the grounds of appeal.

1. According to the facts recognized by the court below, the plaintiff was permitted to conduct cleaning business under Article 11 of the Litter Act and Article 14 (1) 3 of the Enforcement Decree of the same Act on August 13, 1983, 198, and 12 (1) 4 of the Value-Added Tax Act, Article 29 subparagraph 7 of the Enforcement Decree of the same Act, and Article 11-2 of the Enforcement Decree of the same Act on the same day after the plaintiff received a certificate of tax exemption from value-added tax for the cleaning business from 196. 8. 15. 16. 8. 6. 8. 6. 8. 6. 15. 196. 196. 7. 8. 15. 198. 6. 196. 15. 198. 196. 15. 196. 208. 15. 1985. 3. 1. 196.

2. As to the first ground for appeal:

However, Article 15 of the Framework Act on National Taxes provides that "When a taxpayer performs his/her duties, he/she shall be in good faith and in good faith. The same shall apply to the performance of his/her duties." This principle of trust and good faith means that a tax official shall not infringe the interests of the other party who acted in trust in his/her speech and behavior. In general, in tax and law relations, the principle of good faith shall apply to the acts of the tax authority: first, the tax authority shall issue a public opinion that is the object of taxpayer trust; second, the tax authority shall issue a public opinion that is the object of taxpayer trust; second, the taxpayer shall not be responsible for the failure of the taxpayer to believe that the name of the opinion of the tax authority is legitimate; third, the taxpayer shall trust and trust the name of the opinion; fourth, the tax authority shall impose a disposition contrary to the above opinion list; fourth, the tax authority's disposition shall be deemed to be unlawful only when it satisfies all such requirements (see Supreme Court Decision 2005Nu485393, Apr. 23, 1985).

According to the reasoning of the judgment below, on January 25, 1985, after the above cleaning service business was subject to taxation, the court below rejected the plaintiff's certificate of duty-free business operator on January 25, 1985, and confirmed that the same business was exempt from taxation, and thus, the plaintiff knew the above confirmation to the defendant and did not collect value-added tax from the other party as tax-free business until June 13, 1985. Thus, the tax disposition of this case is illegal as a disposition in violation of the principle of good faith under Article 15 of the Framework Act on National Taxes. The principle of good faith stipulated in Article 15 of the Framework Act on National Taxes refers to that the plaintiff's duty-free business operator's duty-free business operator's certificate was inspected after the above cleaning service business was subject to taxation, and it did not err in the misapprehension of legal principles as to the plaintiff's duty-free business operator's duty-free business's duty-free business's act and it did not err in the misapprehension of legal principles as seen above.

As to ground of appeal No. 2

In light of the provisions of Article 197-2 of the Income Tax Act, Article 5 of the Value-Added Tax Act, and Articles 7 through 9 of the Enforcement Decree of the same Act, business registration under the Value-Added Tax Act is intended to enable the tax authority to identify the taxpayer of value-added tax and secure the taxation data (see Supreme Court Decision 83Nu228, Jul. 26, 1983). This is established as a mere report of business fact by submitting a business registration application prescribed by the head of the tax office under the jurisdiction of the business entity. The issuance of the business registration certificate is merely an act of delivering a certificate verifying such registration (see Supreme Court Decision 81Nu416, Jun. 14, 1983). Thus, the censorship of the business registration certificate is merely an act of proving the report of the business entity whose business is registered by the tax authority, and it cannot be said that it is a quasi-legal administrative act confirmed as the taxpayer.

Therefore, the court below's rejection of the plaintiff's assertion that the censorship of the above business registration certificate is a quasi-legal act and thus, it cannot be affected retroactively to the plaintiff even if it is revoked due to its fairness and finality. Therefore, it is justified to have rejected the plaintiff's argument that it cannot be affected retroactively to the plaintiff.

4. Therefore, the appeal shall be dismissed, and all costs of appeal shall be assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices.

Justices Choi Jae-ho (Presiding Justice)