1. The Defendant’s value-added tax for the first term of March 12, 2012 against the Plaintiff on March 12, 2012 was KRW 934,970, and February 2, 2010.

1. Details of the disposition;

A. The Plaintiff is a company established for the purpose of providing online information and providing Internet services.

B. On March 12, 2012, the Defendant issued a revised notice of KRW 934,970 for the first term portion of value-added tax, and KRW 10,743,670 for the second term portion of value-added tax for the second term of 2010 to the Plaintiff.

C. On June 8, 2012, the Plaintiff appealed and filed a petition for a trial with the Tax Tribunal. The Tax Tribunal rendered a disposition on November 8, 2013, which was issued on March 12, 2012, corrected the tax base of value-added tax and the amount of tax calculated by deducting the fees for securities company paid to a securities company from the sales amount.

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According to the above decision, the defendant notified the amount of value-added tax for the second term of 2010 to 6,633,000 won.

[Reasons for Recognition] Unsatisfy, Gap evidence 1 to 3, Eul evidence 1 (including paper numbers; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) The HTS (HTS) is designed to secure the collection of loans and is merely an attempt to deliver customers’ orders to HTS to the securities company’s HTS. Therefore, the principal service provided by the Plaintiff is not a lending of transaction account and a provision of transaction system, but a lending of money. Therefore, this constitutes a service exempt from value-added tax, even if the service provided by the Plaintiff does not constitute a monetary loan business, it constitutes an investment brokerage business, and thus, it constitutes a service exempt from value-added tax.

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

C. 1) The Plaintiff is a securities company’s securities option trading account in its name (hereinafter “instant account”).

After opening this case's account, customer's futures option trading was conducted on behalf of the customer through this case's account.

The Plaintiff’s customer is a security deposit that the instant account deposited with the Plaintiff by the customer.