1. The Defendant’s imposition of KRW 74,253,530, which was imposed on the Plaintiff on December 1, 2014, is subject to the imposition of KRW 74,253,530.

1. Basic facts

A. SH Corporation (hereinafter “SH Corporation”) implemented the Housing Site Development Project in Jung-gu Seoul Special Metropolitan City, Jung-gu, Jung-gu, Seoul Special Metropolitan City (hereinafter “SH Corporation”) by developing the same area as a housing site and supplying national housing, etc. (hereinafter “instant project”).

B. On March 30, 2007, the Plaintiff concluded a contract for the instant project complex development project under the Act on the Construction of Housing Site Development Projects for New District Two Zones that created the instant project complex by setting the construction period from April 5, 2007 to October 4, 2009, with the Defendant as KRW 13,324,094,050.

C. However, on August 2007, when SH Corporation constructs national housing and general multi-family housing together in a single project district, the Seoul Special Metropolitan City considers that it is subject to value-added tax exemption equivalent to the ratio of the area of the national housing project district to the area of the national housing project district among the construction services, and the same year.

9.3. Along with the guidance of the SH Corporation to modify the construction contract with the contractor.

On December 31, 2007, the Plaintiff entered into a modified contract with SH Corporation for the adjustment of the initial construction amount. Among the supply cost of services provided during the first taxable period in 2010 (hereinafter “instant services”), the Plaintiff reported and paid the current value-added tax (excluding KRW 411,536,524 equivalent to the percentage of the supply area of national housing among the supply area of national housing within the instant project district, among the supply cost of services provided during the first taxable period in 2010 (hereinafter “instant services”).

E. However, on December 1, 2014, the Defendant: (a) deemed that the entire instant service did not constitute value-added tax exemption; and (b) rendered a disposition imposing the Plaintiff KRW 74,253,53,530 on the sum of value-added tax of KRW 41,153,652 and penalty tax of KRW 33,09,878 (hereinafter “instant disposition”).

F. On January 7, 2015, the Plaintiff filed a petition with the Tax Tribunal for an inquiry on the instant disposition, but the same year.

3.10. Requests from the Tax Tribunal.