1. All appeals by the Defendants are dismissed.

2. The costs of appeal are assessed against the Defendants.

Purport of claim and appeal

1.

Details of the disposition

The reasoning for this Court’s explanation is as follows, except for the following amendments, i.e., from 8 to 3 last deeds in the first instance court’s judgment: (a) the developments leading up to the disposition is as stated in Article 8(2) of the Administrative Litigation Act; and (b) the text of Article 420 of the Civil Procedure Act.

The term "asset management project" in the 3th below shall be changed to "asset management project".

3 The last 3 pages of the “Entrys A(1) through (4)” shall be deemed to read “entrys A(1) through 5(if any, including each number; hereinafter the same shall apply)”.

2. Whether the disposition is lawful;

A. The Plaintiffs’ primary assertion 1) Claim collection services provided to the desired mother under the instant contract (hereinafter “instant services”).

(2) Even if the instant services do not fall under Article 33(1)15 of the former Enforcement Decree of the Value-Added Tax Act, the Plaintiffs provided the same or similar services as the financial and insurance services under Article 33(1)15 of the former Enforcement Decree of the Value-Added Tax Act, and thus, constitute tax-free claims. (2) Even if the instant services do not fall under Article 33(1)15 of the former Enforcement Decree of the Value-Added Tax Act, the instant services constitute tax-free claims pursuant to Article 33(2) of the said Enforcement Decree.

(b)as shown in Appendix 2 of the relevant statute.

C. Under the relevant provisions and the principle of no taxation without law, the interpretation of tax laws shall be interpreted as a legal text, barring special circumstances, and it shall not be allowed to expand or analogically interpret without reasonable grounds.

However, if it is necessary to clarify the meaning through the interpretation between laws and regulations, the legal stability and predictability oriented by the principle of no taxation without law.