Expenses incurred by the services are common purchase tax amount related to the overall redevelopment project.

Comprehensively taking account of the contents of the service, the service required at a series from the commencement to the completion of the housing redevelopment project is not for the acquisition of the land for the housing redevelopment project, and the relevant input tax amount is not for the land-related input tax amount.

Article 60 of the Enforcement Decree of the Value-Added Tax Act

2015Guhap51600 Disposition to revoke the imposition of value-added tax

In full view of the contents of the service, the service shall begin and complete from the commencement of the housing redevelopment project.

up to a series of stages required for housing redevelopment projects as a whole;

not only for the acquisition of land for housing redevelopment projects, but not for the acquisition of land for housing redevelopment projects.

The input tax amount on the whole project of this case is not the purchase tax amount related to the land, but the common purchase tax amount on the whole project

Therefore, the prior disposition of this case is unlawful on a different premise.

① On June 14, 2010, the Plaintiff entered into a service contract with the JICC, and the Plaintiff’s business.

the public relations of owners of land, etc., education of public relations personnel, written consent to the promotion committee and written consent to the establishment

It is called "regument".

② On February 20, 2008, the Plaintiff entered into a service contract with the ENI Construction Co., Ltd., and the said company

The work is to prepare a detailed statement for the establishment of a rearrangement zone (such as a cadastral survey), approve the establishment of an association;

It is an association authorization, project implementation authorization, preparation of management and disposal plan, and preparation of other documents.

③ On May 31, 2007, the Plaintiff entered into a service contract with the GH Engineering General Certified architect office.

The business of the above company is called "maintenance plan, designation of the rearrangement zone, environmental review, traffic review and competition."

It is called ‘government', ‘cultural property surface inspection', etc.

④ On May 9, 2011, the Plaintiff entered into a service contract with the LAW and the said company.

The work is ‘consulting on the environment, noise, right to sunshine'.

⑤ On May 2, 2011, the Plaintiff entered into a service contract with DH cadastral survey committee, and the said company.

The work is ‘survey on the actual survey of the building and topographical survey'.

④ On May 9, 2011, the Plaintiff entered into a service contract with the Korea Development Bank Co., Ltd., and the business of the said company

There is a 'brupt investigation'.

7. On May 3, 2011, the Plaintiff entered into a service contract with the Korea Research and Development Institute for the Bank of Bankruptcy, and the said company

The work is ‘traffic impact analysis and improvement plan formulation'.

8. On May 11, 2011, the Plaintiff entered into a service contract with GHHC, and the business of the said company.

It is the ‘public announcement of the modification of the promotion plan and the formulation and modification of the promotion plan'.

9. On May 12, 2011, the Plaintiff entered into a service contract with the design author, and the business of the said company

It is ‘the work related to the preparation of a review book and the review of landscapes'.

(10) On May 3, 2011, the Plaintiff entered into a service contract with the BA engineering company, and the said company.

The work is ‘the survey of stolen property'.

11. On May 11, 2011, the Plaintiff entered into a service contract with the JWABC, and the said company.

The work of the Council is an eco-environmental review.

(12) On May 31, 2007, the Plaintiff entered into a service contract with the JMMND, and the said company's business.

Free is ‘business affairs of the promotion committee, designation of the improvement zone, authorization for establishment, authorization for project implementation, management and disposal'.

(13) Real estate development tax invoices received by the plaintiff from the DHP franchise on November 3, 2011

The OS service cost is about OS service cost.

3. Conclusion

If so, the plaintiff's claim is reasonable, and it is decided as per the disposition.

(c)

AA

The Director of Incheon Tax Office

September 10, 2015

October 22, 2015

1. On November 1, 2014, each imposition of value-added tax (including additional tax) 106,882,880 won, and value-added tax (including additional tax) 36,685,940 won for the second period of 2011 against the Plaintiff shall be revoked.

2. The costs of the lawsuit are assessed against the defendant.

The same shall apply to the order of the Gu office.

1. Details of the disposition;

A. On April 15, 2007, the Plaintiff is an association with the approval of the establishment promotion committee from the head of Nam-gu Incheon Metropolitan City, and with the approval of the establishment of the association on October 4, 2010.

B. In promoting a housing redevelopment project in the first and second stages of the Value-Added Tax in 2011, the Plaintiff received the purchase tax invoice of KRW 4,137,50,484, total supply value of KRW 4,137,50,484 from JIC, etc., and received the purchase tax invoice of KRW 413,75,047, which is the common purchase tax amount for the tax-free business, and thus, received a refund of KRW 139,683,442, which is the input tax amount excluding KRW 274,071,60,605, which is the input tax amount related to the tax-free business, through the final return and rectification of the value-added tax (hereinafter referred to as “tax invoice”). The Defendant, upon conducting a corporate integration investigation with the Plaintiff around July 2014, deemed the common purchase tax invoice of KRW 2,763,552,000 (hereinafter referred to as “instant tax invoice”) and excluded KRW 13016,213081,20816.

D. The Plaintiff dissatisfied with the instant disposition and filed a request for examination on February 9, 2015, but the Commissioner of the National Tax Service dismissed the request on April 7, 2015.

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[Ground of recognition] The facts without dispute, Gap evidence Nos. 1 through 4 (including the branch numbers in the case of additional numbers), Eul evidence Nos. 1 and 2 (including the branch numbers in the case of the evidence No. 1), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

The instant services provided by the Plaintiff from JIC, etc. do not constitute capital expenditures for the creation, etc. of land, etc. as services and consulting services necessary for redevelopment projects, such as the establishment of a written consent, establishment of maintenance plans, etc., and thus, the instant disposition is unlawful, excluding all of the instant services from the input tax amount subject to deduction.

(b) Related statutes;

Attached Form is as shown in the attached Form.

C. Determination

1) Article 17(2)6 of the former Value-Added Tax Act (amended by Act No. 11129, Dec. 31, 201; hereinafter referred to as the “Act”) concerning the business of supplying goods or services exempt from value-added tax as one of the input tax amounts not deducted from the output tax amount (investment)

Article 60(6) of the Enforcement Decree of the Act (amended by Presidential Decree No. 23595, Feb. 2, 2012; hereinafter referred to as the "Enforcement Decree") provides that the input tax amount related to the acquisition and alteration of the form and quality of the land, the construction of the factory site and the housing site, etc., falling under any of the following subparagraphs shall be the input tax amount related to the capital expenditure for the creation, etc. of the land, and Article 17(2)6 of the Act provides that the following input tax amount is the input tax amount related to the acquisition of the land, the alteration of the form and quality of the land, the construction of the housing site and the housing site, and subparagraph 2 of Article 2 provides that the input tax amount related to the expenses for the acquisition and removal of the removed building, and subparagraph 3 provides that the input tax amount related to the expenses that constitute the acquisition cost of the land is the input tax amount.

2) The following events are acknowledged by each description of Gap evidence 3 and 4 (including each number):