1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. The Plaintiff is a company whose business purpose is the banking business under the Banking Act.

B. The Plaintiff received management support services for various items such as personnel affairs, finance, risk management, computer support, etc. (hereinafter “instant services”) from the management support centers affiliated with the CT Group (referring to the Governing Headquarters of the United States, the United Kingdom, Hong Kong, etc., and the management support centers within each regional headquarters (hereinafter “management support centers”) and paid the price therefor.

The Plaintiff reported and paid value-added tax from the first to the second half of 2014, on the ground that the payment made to the management support center is subject to substitute payment under Article 34 of the former Value-Added Tax Act (wholly amended by Act No. 11873, Jun. 7, 2013; hereinafter the same shall apply) and Article 52 of the Value-Added Tax Act.

C. The Plaintiff determined that the instant service constitutes a service provided abroad, and thus, it is not subject to the payment by proxy under the Value-Added Tax Act, and rendered a request for correction as indicated in the column of “amount of tax requested for correction” in the attached Table [Attachment] with respect to value-added tax from the first to the second half of 2014.

Accordingly, the Defendant rejected the Plaintiff’s claim for correction (hereinafter “instant rejection disposition”), and the Plaintiff filed an appeal with the Tax Tribunal, but the said claim was dismissed.

[Reasons for Recognition] Facts without dispute, each entry of Gap evidence 1 to 3 (including each number), and the purport of the whole pleadings

2. Judgment on the Defendant’s main defense

A. Article 45-2(1) of the Framework Act on National Taxes provides that only a person who has filed a tax base return by the statutory due date of return may file an application for rectification, and the return on the substitute payment of value-added tax does not fall under the tax base return.