1. All appeals filed by the plaintiffs are dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning for the court’s explanation of this case is as follows, except for the addition of “determination of the plaintiff’s assertion of the trial” under Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act, thereby citing this as is in accordance with the reasoning for the judgment of the first instance.

2. Determination as to the plaintiffs' assertion of propriety

A. The plaintiffs asserted that the disposition of this case imposing value-added tax on this portion of the land belonging to the State among the reclamation services provided by the plaintiffs for the following reasons (hereinafter "instant services") is unlawful, notwithstanding that the land belonging to the State is not subject to value-added tax.

1) Of the instant services performed pursuant to the instant project, the land reverted to the State free of charge is subject to the former Value-Added Tax Act (amended by Act No. 11129, Dec. 31, 201; hereinafter “former Value-Added Tax Act”).

2) Article 12(1)19 of the former Value-Added Tax Act provides that “The supply of services to another person without compensation,” which constitutes “the supply of services without compensation,” and thus cannot be deemed as a supply of services subject to value-added tax.”

B. In the event that a supplier of the instant reclamation service and the service subject to value-added tax acquired ownership of a part of the land created by reclamation in accordance with the relevant statutes and the agreement between the parties after obtaining a license from the State for the implementation of the reclaimed land creation work and obtaining authorization for the completion thereof, the said supplier provided the State with the above-mentioned land reclamation work.