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1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
Reasons
1. Details of the disposition;
A. On December 5, 1995, the Plaintiff is a taxable entrepreneur with the establishment of a joint investment by Busan Metropolitan City, the Korea Trade-Investment Promotion Agency, and private enterprises for the efficient implementation of the exhibition conference project. On May 28, 2007, the Plaintiff is a taxable entrepreneur with the establishment of the first exhibition and convention hall, which is an international exhibition facility, on land owned by Busan Metropolitan City located in 1500, Busan High-dong Busan High-dong, Busan High-dong, and holds a domestic and foreign exhibition and exhibition conference.
B. The Plaintiff received subsidies of KRW 10,368,756,273 (hereinafter “instant subsidies”) from the Busan Metropolitan City and the Ministry of Trade, Industry and Energy during the period from February 2, 2008 to February 2, 2012, while running an agency business, such subsidies were deemed subsidies not included in the tax base pursuant to Article 13(2)4 of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013; hereinafter “former Act”), and thus, was not included in the tax base at the time of the return of value-added tax for each of the pertinent taxable periods.
C. As a result of conducting a regular tax investigation with respect to the Plaintiff from July 8, 2013 to July 26, 2013, the Defendant: (a) deemed the instant subsidy that the Plaintiff received while holding exhibitions, etc. as not being included in the tax base pursuant to Article 13(2)4 of the former Act, to be subject to value-added tax; and (b) deemed that it constitutes the price that the Plaintiff received for services provided to Busan Metropolitan City, the Ministry of Trade, Industry and Energy, etc.; (c) on October 7, 2013, value-added tax of 2,76,453,700, value-added tax of 1,391,050, value-added tax of 2,205, value-added tax of 2,105,96,90, 171, 303, value-added tax of 1,303,150, 2010, 216, 2196, 2016, 2016