1. All of the plaintiffs' claims are dismissed.

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

1. Details of the disposition;

A. On July 16, 2014, the Plaintiffs were registered as business operators for the operation of solar power generation business, and entered into a construction contract with the Gold-solar Power Plant Co., Ltd. (hereinafter “instant company”) under which the instant company contracted the installation of solar power plants (hereinafter “each of the instant contracts”) and the construction price for each of the instant contracts is as indicated below. The instant contracts are as follows. The solar power plants supplied under each of the instant contracts are “each of the instant electric power stations,” the installation of solar power plants under each of the instant contracts, and the installation of solar power plants under each of the instant contracts are as follows.

Plaintiff

AD 212,263,000 21,226,300 B E 223,489,300 B 223,872,000 22,387,200 246,259,200 CF 205,469,000 20,546,900 226,015,900

B. On January 15, 2015, the Plaintiffs received each tax invoice based on the supply price of each of the above construction costs from the instant company, and filed a scheduled value-added tax return by deducting the tax amount under each of the instant tax invoices from the input tax amount in the first taxable period of 2015.

Plaintiff

On January 15, 2015, 212,263,000 B E on January 15, 2015, 223,872,387,200 CF on January 15, 2015, 205, 205,469,000,000,547,900

C. From May 19, 2015 to May 26, 2015, the Defendant conducted on-site verification with respect to the Plaintiffs, and deemed that the time of supply for each of the instant construction services was the date when the Plaintiffs issued a certificate of pre-use inspection with respect to each of the instant electric power plants on August 2014, which was when the certificate of pre-use inspection was issued by the Plaintiffs.

Accordingly, on August 1, 2015, the Defendant deemed that each of the instant tax invoices was issued after the time of supply, and thus, deemed that the input tax amount was not deducted from the output tax amount for the first period in 2015, and the value-added tax (including additional tax) for the Plaintiffs on August 31, 2015, as the payment period, shall be as follows.