The plaintiff's claim is dismissed.

Litigation costs shall be borne by the plaintiff.

1. Details of the disposition;

A. The Plaintiff, a corporation operating a travel business, handled only free travel without Grandland (referring to a company that proceeds from transportation, lodging, meals, tourism, etc. in local areas) as a matter of principle.

First, in light of the evidence No. 9-3, evidence No. 10-1, No. 2, 3, and evidence No. 111, it seems that the trip through Ireland was also treated;

Free travel (only rights and reservations related to aviation, hotel accommodation, local traffic, etc.), and other travel schedules are planning and selling overseas travel goods, such as meals and tourism through Grandians, by free decision of travelers.

B. The Plaintiff reported and paid, respectively, value added taxes from January 2013 to February 2017, on the basis that the amount equivalent to 10/11 of the remainder of the commission, which deducts direct expenses, such as air expenses, transportation expenses, lodging expenses, food expenses, etc., (hereinafter “instant commission”) among the remuneration that the Plaintiff sold overseas travel goods to customers (a contract concluded with the Plaintiff while selling overseas travel goods (hereinafter “foreign travel contract”).

(c)

Article 11(1)2 and 3 of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013) (wholly amended by Act No. 11873, Jun. 7, 2013) that applies up to 22, Article 23-2 of the Value-Added Tax Act, as a travel service or a navigation service supplied overseas to customers (i.e., transportation, lodging, meals, tourism, etc. (hereinafter “instant service”).

The following Acts and subordinate statutes shall be governed by the current Acts and subordinate statutes for convenience.

The zero tax rate shall be zero.

The Defendant, on July 24, 2018, refund of KRW 4,233,708,176, the sum of value added taxes reported and paid in relation to the sale of overseas travel products, from January 2013 to February 2017.