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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. The Plaintiff, a corporation that is conducting a foreign language education project for elementary, middle and high school students, established Chungdahm Whites. Inc. (hereinafter “the subsidiaries of this case”) in the Philippines.
The Plaintiff entered into an agreement with the instant subsidiary on the addition and evaluation services in English with the instant subsidiary. The instant subsidiary provided the Plaintiff with the addition and evaluation services in English as the Plaintiff prepared and submitted by the Plaintiff’s domestic students through a local lecturer in the Philippines (hereinafter “instant services”).
B. The director of the Seoul Regional Tax Office notified the Defendant of the taxation data stating that “The instant service provided to the Plaintiff by the instant subsidiary without a domestic place of business constitutes the supply of the service subject to value-added tax, and the Plaintiff is liable to pay value-added tax on the supply of the instant service by proxy under Article 34 of the former Value-Added Tax Act (amended by Act No. 9915, Jan. 1, 2010). Accordingly, the Defendant imposed and notified the Plaintiff of the value-added tax (including additional tax)
(hereinafter “instant disposition”). C.
Accordingly, the Plaintiff filed an objection with the Seoul Regional Tax Office or filed a request with the Tax Tribunal as follows, but all of the decision was dismissed.
A petition for a trial filed on April 16, 2015, the second period of the trial before the date of a disposition in the taxable year; the petition for a trial filed on May 28, 2015; the petition for a trial filed on August 31, 2015; the petition for a trial filed on December 31, 2015, the first period of the appeal filed on September 1, 2015; the petition for a trial filed on December 31, 2015; the petition for a trial filed on December 31, 2015, the second period of the second period of the 2010, the second period of the 2015, the second period of the 2010, the second period of the 2015, the petition for a trial filed on July 6, 2015; the petition for a trial filed on December 31, 2015, the first period of the 2015, the first period of the 2015.