1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On May 18, 2005, the Plaintiff reported a remote education-type lifelong educational establishment in accordance with the Lifelong Education Act, and entered into a telephone fishing service contract with the Non-C&M business call center, which has its head office in the Philippines during the 1st VAT period in 2009, (BC UPPHHHHHE CAL CALE CANE CAE INC; hereinafter referred to as the “ Philippines corporation”), and the Philippines corporation provides the Plaintiff’s participants with telephone fishing lectures in accordance with this contract.

B. On July 1, 2014, the Defendant imposed value-added tax of KRW 48,989,910 for the first half of the year 2009 on the ground that telephone fishing services provided to the Plaintiff to a corporation of the Philippines was subject to value-added tax by proxy.

(hereinafter “Disposition in this case”). / [Grounds for recognition] without dispute, entry of Gap evidence Nos. 1 and 2, and purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The instant telephone fishing service supplied by a corporation of the Philippines, which is an educational institution duly registered and permitted by the Plaintiff’s assertion and local law, is exempt from the Plaintiff’s duty of vicarious payment.

(b) as shown in the attached Form of the relevant statutes;

[2] The former Value-Added Tax Act (amended by Act No. 9915 of Jan. 1, 2010) (hereinafter “former Value-Added Tax Act”).

Judgment

Value-added tax shall be collected and paid when services are provided and paid by a foreign corporation with no domestic place of business.

(Article 34 (1) of the former Value-Added Tax Act). On the other hand, educational services provided by a private teaching institute, etc. permitted or authorized by the Government to students constitutes tax-free

(1) In addition to the purport of the entire pleadings, Article 12 of the former Value-Added Tax Act and Article 30 of the Enforcement Decree of the same Act, the Plaintiff entered into a service contract with the Switzerland corporation and the Switzerland corporation to pay the Plaintiff the price when providing telephone fishing services to the Plaintiff students.