Seoul Administrative Court 201Guhap29625, 012 04.13

Cho High Court Decision 201Do1035 (No. 2011.08)

Loan recruitment services are not exempt from value-added tax;

(1) The Plaintiff’s entrusted loan solicitation business is merely an incidental business to the loan lending business, and insofar as the Plaintiff, who has a third-party position against the financial service provider, independently conducts the loan solicitation business, which is an incidental business to the mutual savings bank business or the money lending business, it does not constitute a tax-exempt business, “mutual savings bank business” or “other money lending business.”

Article 12 of the Value-Added Tax Act

Article 33 of the Enforcement Decree of the Value-Added Tax Act

2012Nu13902 Revocation of Disposition of Revoking Value-Added Tax Correction

XX Co., Ltd

Head of Central Tax Office

Seoul Administrative Court Decision 2011Guhap29625 decided April 13, 2012

July 25, 2012

August 22, 2012

1. The plaintiff's appeal is dismissed.

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

The judgment of the first instance shall be revoked. The defendant's dismissal of the value-added tax claim against the plaintiff on November 30, 2010 shall be revoked.

1. Advice with the judgment of the court of first instance;

The reasons why this Court is used for this case are as follows: The reasons for the judgment of the court of the first instance shall be as follows: Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act shall be cited.

From the second 6th to the second 8th 'day', several mutual savings banks (1, 2, 11, 2008, 1, 2, 14, 2010, 16, and 201) enter into an entrustment contract with each other savings bank (2, 209, 12, 2010, 200) to provide money lending services, and 'OO', etc. in total with mutual savings banks (2, 209, 2010, 1, 2010, hereinafter referred to as "O', etc.") to receive loan application, provide related data such as personal information of applicants for loan examination, confirm personal signature of applicants for loan, transfer of loan documents, etc., and provide loan recruitment services to Os, etc. for loan recruitment services.

O 3rd 4th (based on recognition) add "A No. 8" to the column.

O The proviso of Article 33(4) that will be the 14th term "the proviso of Article 33(4)" is "the proviso of Article 33(4)1."

O's 4th place on the "O, etc." means "O, etc.".

I examine the case in question with the fifth seventh day of the trial. "In full view of the whole purport of the arguments in the evidence Nos. 2 and 8, I examine the case."

O's 9th 8th 'Value-Added Tax Act' is the Value-Added Tax Act (before it is amended by Act No. 11129 on December 31, 201).

O The Enforcement Decree of the Value-Added Tax Act, which will be the 25th half of the first place, is "Enforcement Decree of the Value-Added Tax Act" (amended by Presidential Decree No. 22578, Dec. 30, 2010).

2. Conclusion

The appeal is dismissed.